The appellant, Daniel Kenwright, went to the First Tier Tribunal (FTT) to ask for permission to make a late appeal over a personal liability notice (PLN) issued by HMRC in 2020, which totalled £56,986.16.

However, Kenwright waited more than 425 days (14 months) after the statutory time limit of 30 days to file his notice of appeal.

On 2 October 2020, HMRC wrote to Bar Signature Limited with a series of assessments for VAT, totalling £107,761.21. These assessments were imposed for failing to provide ‘satisfactory evidence’ to support claims to credit for input tax.

HMRC later issued a penalty explanation later on 14 October 2020, explaining that it intended to charge a penalty for submitting inaccurate returns.