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PLNs
PLNs
On 8 November 2018, having received information that Da Remo Restaurants Ltd was about to be liquidated, HMRC issued it with a “deliberate” penalty of £21,552 relating to VAT inaccuracies; on the same day it issued Mr Di Lellio with a PLNof 100% of the penalty.
On 25 January 2019, HMRC issued the same company with a further deliberate penalty of £2,728.02, this time relating to CT, and on the same day, issued Mr Di Lellio with a PLN of 100% of the penalty.
No appeal was made for or on behalf of Mr Di Lellio against those PLNs.In April 2020, HMRC carried out a statutory review of the CT and VAT assessments and withdrew them. Later the same month HMRC cancelled the related penalties. As at the date of the hearing, the PLNs remained extant.
- Heading
- Introduction and Summary
- The Evidence
- Findings of fact
- Tax years 2011-12 and 2012-13: assessments
- Tax years 2013-14 to 2015-16: assessments
- The Form
- Mr Di Lellio’s diagnosis
- Penalties for inaccuracies
- PLNs
- Subsequent events including bankruptcy proceedings
- Jurisdiction of the Tribunal
- The legislation about appeals
- The discovery assessments
- The closure notice amendments
- The steps taken by the parties
- The timing of the Application
- The Case Law
- The first Martland stage: the delays
- The second Marland stage: reasons for delays
- Reliance on advisers
- The need for time limits to be respected
- Merits
- Other prejudice to Mr Di Lellio
- Prejudice to HMRC
- Other Tribunal users
- Conclusions