Stanley Augustine Hermann spent 10 years in prison, from 2002-12, but was still receiving rental income from three properties for the length of time. However, no income tax was declared leading HMRC to open discovery assessments into the landlord and issuing penalties.

It was not just the 10 years Hermann was in prison HMRC assessed him on, the assessments and penalties stretch from 2002/03 to the 2017/18 tax year. The three properties in question were bought by the appellant in 2000 and 2001, and he lived in one of them for a time and let the other two.