Sub contract client was used to getting refunds of around £1500, but then in 2004/05 due to personal difficulties he quit work and failed to submit a final return.
Eventually HMRC raised a determination for 3k. He still did nothing until 2011 he filed a return showing a nil liability.
HMRC say that the determination still stands and there is no right of appeal, are they correct?
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Maybe still worth a shot
If the Return was submitted prior to 1 April 2011 it would be worth arguing that at the time Equitable Liability applied and the Determination should have been reduced to Nil. You can still try a claim for Special Relief. Some more info here http://www.hmrc.gov.uk/manuals/sacmanual/SACM12210.htm