Heaven Dry Cleaners (HDC), on North End Parade, London, received a conclusion letter from HMRC about its corporation tax in December 2019, while a VAT conclusions letter was received in August 2021.

Hamidreza Nikoukarmojarad has been the sole director of HDC since 2009 and gave evidence at the tribunal.

In total, the corporation tax and VAT bills, along with penalties came to £491,962, although the penalties were not included in the letters, and remain under review by HMRC.

Firstly the tribunal had to determine whether HDC were in time to appeal.