HMRC have every right to go after tax that is due if they deem it is payable. Whether they take it to the first tier, second tier or wherever, if they believe they can prove the tax is due, why not?
We do it with clients when money is due, HMRC may not be a business but with so much to collect I understand why they go after the big ones, my problem with HMRC is they try to go after the little guys first!!
we manage to make a great profit still from formations. if your client wants you to do it charge the time for it.