.png)
.png)
In February 2018 the taxpayer’s agent notified HMRC of a client’s liability to tax for 2016-17. Their letter stated: ‘We are writing to give notice of liability to tax under TMA 1970 s 7(1) for tax year SA17’. It did not provide details other than to say the client had reasonable excuse for the late notification and to ask that a late notice penalty not be issued.
In October 2021 HMRC wrote to the taxpayer and the agent saying it understood she was receiving rental income and asking for more details. In December 2021 the department issued a further request for information in the form of a notice under FA 2008 Sch 36.
The agent provided some of the information requested. After more correspondence HMRC issued discovery assessments for the years 2016-17 to 2020-21 and penalties.
The taxpayer appealed. The agent said the...
