Sheiling Properties Ltd v The Commissioners for HM Revenue and Customs: [2020] UKUT 0175 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Trower and Judge Thomas Scott on 8 June 2020.
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INCOME TAX penalty for non-payment of accelerated payment notice is tax demanded under a Regulation 80 PAYE determination disputed tax within APN provisions yes did taxpayer have a reasonable excuse for non-payment of penalty no circumstances in which belief that APN was procedurally invalid could constitute reasonable excuse appeal dismissed.