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The issues to be determined
The issues to be determined
The issues for us to determine are whether:
The Discovery Assessments have been properly raised and are in time.
HMRC have correctly assessed the penalties for failure to notify chargeability.
If penalties are due, whether the Appellant has a reasonable excuse for failing to notify her chargeability to the HICBC and/or whether there are any special circumstances such that HMRC should reduce or cancel the penalties.
The burden of proof is on HMRC to show that it is more likely than not that it has discovered a loss of tax and that the penalties have been correctly charged.