In Pitcher, the First-tier Tribunal has overturned a penalty for non-compliance with an accelerated payment notice. The tribunal was unable to consider the conditions for the issue of the notice or even how the accelerated payment was calculated, but the failure to be clear as to the amount due meant that HMRC was not entitled to impose a penalty for non-payment. The appellant was successful, but the decision emphasises both the difficulty in overturning accelerated payment notices and also the importance of scrutinising accelerated payment notices to ensure they are clear and complete.
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