At the First Tier Tribunal, the appellant, Dr Nwaneri appealed against HMRC penalties and closure notices related to three years of work at various NHS Trust hospitals where he claimed expenses without substantiating documentation.

The appeal centred around whether his behaviour was deliberate, with the tribunal reviewing the claims and evidential basis, with cross examination of the appellant, who did not have representation.

In April 2024 HMRC issued enquiry notices to Dr Nwaneri under section 9A Taxes Management Act 1970 for tax years 2019-2020 to 2021-22. These included amendments with HMRC removing the expenses claimed by the appellant, in one instance totalling £30,393.40.

At the same time, the HMRC officer also requested documentation to substantiate the expenses claims.