Colin Sagar v The Commissioners for HMRC

Facts

Mr Colin Sagar, acting in person, brought two appeals to the First-tier Tribunal (Tax Chamber) against HMRC. The first, the Input Tax Appeal, challenged HMRC's decision denying his claim for input tax for the VAT periods ending in March, April and May 2021, a decision reached after a lengthy compliance check during which he had supplied HMRC with documents and information, including an email of 20 February 2022 attaching sales invoices, customer agreements and related correspondence. The officer who conducted the compliance check had left the department by the time the appeal began. HMRC filed a Statement of Case on 19 August 2024, maintaining that the evidence provided was insufficient, and sought copies of documents it said it could not locate; Mr Sagar maintained the material had already been supplied. Preparation continued until 7 February 2025, when HMRC withdrew the decision under appeal, and the Tribunal struck out the appeal while preserving his entitlement to apply for costs. The second, the Penalties Appeal, concerned two Personal Liability Notices and associated penalties issued in September 2024 and appealed on 22 September 2024; HMRC reviewed the matter, concluded the penalties had been issued in error, and withdrew before serving a Statement of Case. Mr Sagar applied for costs in both appeals, seeking indemnity costs and a wasted costs order.