The appellant, Roscoe Noonan was hit with a VAT assessment of £600,832.46 in 2020 under section 73 of the VAT Act 1994, as well as penalties, for suppressing sales between 2008 and 2018.

The original letter from HMRC, dated 21 May 2021, gave Noonan 30 days to appeal, however, he submitted the appeal late three months’ late on 19 September 2021.

It was decided that because of the pandemic the appeal would be allowed as HMRC was allowing three months at this time.

Judge Rachel Gauke said: ‘In the circumstances of this case, we consider that it is in the interests of justice to allow the appeal to be made late, and we grant permission accordingly.’

Noonan would purchase most of his cars from West Oxfordshire Motor Auctions (WOMA) between 2008-14, allowing two of his associates to purchase cars at this auction through his account for the auction site.