Lee Sharpe worries that tribunals seem to have become increasingly indifferent to taxpayers who are struggling to pay HMRC while waiting for repayments, etc. – often from HMRC itself.
Fewer things in life are more annoying than someone, who actually owes you more money, demanding payment. But this is quite common with HMRC, across the various heads of tax: waiting for a refund to set against a liability elsewhere. To add insult to injury, HMRC will typically issue a penalty for late payment without regard to those repayments subject to its tender mercies.
Is it ‘reasonable’?
It is a common and enduring principle that a taxpayer who wants to challenge a penalty for late payment (amongst other things) may have a ‘reasonable excuse’ for failing to pay on time. However, it is also a common feature that the law does not permit a mere ‘insufficiency
