This case at the First Tier Tribunal concerned an application by appellant David George Davies for permission to make a late appeal against income tax assessments relating to seven tax years from 2011-12 to 2017-18 and penalties for failure to notify liability for income tax, for tax years 2011-12 to 2015-16.

HMRC conducted a compliance check on Davies in July 2017 after discovering that he was running a pub and receiving income from rental properties but had not been reporting any income tax to HMRC, with total unpaid tax and penalties amounting to £100,000.

During the course of the compliance check, Davies was being advised by an accountant who he had appointed on the basis that this fellow did the accounting for two other pubs in Neath.