Advice re 2010/11 SA penalties on commencement of a trade

Dear all

A new client registered as self employed (on cwf1) from 8 Mar11 and, subsequently, commenced trading on 23 Mar11. Year 1 accounts will be made up to 31 Mar12, however, HMRC issued a SATR and have since levied penaties of £100, £900 and £300 (total - £1,300).

My queries are:

1 - can the client argue that a 2010/11 self assessment cannot be determined until the Mar12 accounts have been prepared (as is the case)?

2 - if an assessment is required for the period from 23 Mar11 - 5 Apr11 is there a firm/valid basis for an appeal against the penalty?

The client was also working abroad for the 6 month up to 13 Jul12 and therefore had difficulty dealing with the penalties when eventually becoming aware of them

All comments will be appreciated

Lew