Sometimes you have to stand your ground!
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Is there no internal review procedure at HMRC?
Apparently there was: "Mr Symon’s view was upheld by the Review Officer."
But see my other reply!
The judge went close to calling the HMRC officer a liar:
"Miss Marshall produced the following documents to the Tribunal that she said she had shown to Mr Symon during the site visit but which Mr Symon had said were not sufficient evidence of the nature of the payments."
"In evidence Mr Symon said he had no recollection of being shown these documents."
"I consider Miss Marshall’s version of events to be more than likely to have occurred because the meta data of the Documents shows they were created in 2016 just before the making of the payments and Miss Marshall had said during the site visit that they were loans."