In this case at the First Tier Tribunal (FTT) the appellant brought an appeal against a penalty for late interest of £219,284, arguing it should be overturned due to circumstances beyond his control which meant he was unable to pay his tax on time.

His 2021-22 tax bill was settled over six months late, as the appellat argued he had insufficient funds due to existing financial commitments, failure to realise investments and sell some companies, and a huge hike in interest rates due to the outbreak of war in Ukraine.