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HMRC internal manual

Enquiry Manual

Information Powers: Tax Cases: Kempton v Special Commissioners and C.I.R. 66 TC 249

The point at issue was a penalty for failure to comply with a S20 notice. One ground for appeal was that the requirements of the notice were unreasonably wide and compliance would have cost Mrs Kempton around £20,000. Mummery J at p265 comments that the Revenue in applying its procedures would recognise the need to keep to a minimum the costs of complying with the Revenue’s requirements.

He continued that there is a presumption of regularity which applies to the decision to issue the notice and the consent given by the General Commissioners…. . There was no evidence from the taxpayer that the Inspector had failed to take any account of the expense of compliance with the notice.