I have recently taken on a new client who was in arrears with his Tax Returns. During his interview with me he produced two letters from the Revenue which were penalty determinations for 2004/2005 and 2005/2006. I subsequently submitted the outstanding tax returns with an appeal against the penalty determinations on the grounds that refunds were due for both tax years.
The Revenue have now written back to me "please note that I do not consider that the submission of the 2004/2005 & 2005/2006 Tax Returns are valid grounds for appealing against the 2004/2005 and 2005/2006 charges raised under section 93(3) TMA1970."
Can anyone suggest why my reasons were not valid and perhaps include reasons which would be valid in the eyes of the Revenue.
Your attention is appreciated.