The appellant, Vitalie Milasenco, appealed at the First Tier Tribunal (FTT) against an HMRC closure notice and discovery assessments for the tax years 2013-14 to 2016-17, which totalled £19,067.

He also disputed inaccuracy penalties and a failure to notify penalty of £9,341, which HMRC issued on the basis that he had ‘deliberately delivered’ inaccurate self assessment returns and failed to notify he was liable for income tax.

According to Milasenco, he had no income from online trading during the relevant tax years and he claimed he was being harassed by HMRC.