Lewis Conman v The Commissions for HMRC

Facts

The appellant, Lewis Conman, was the subject of a Personal Liability Notice issued by HMRC on 5 February 2024, a copy being provided to the liquidator. The notice arose from a Failure to Notify penalty that HMRC had told LVC Global Ltd on 19 December 2023 would be imposed under Schedule 41 to the Finance Act 2008, as applied by paragraph 13 of Schedule 16 to the Finance Act 2020. HMRC's position was that the reference pay used in certain CJRS claims had been increased after the relevant reference date and subsequently reduced once the claims ceased. LVC Global Ltd entered voluntary liquidation on 11 January 2024. On 6 March 2024 the appellant's agent emailed HMRC indicating acceptance of HMRC's position on the CJRS overclaim. On 27 and 29 May 2025 the appellant notified two appeals to the Tribunal against the same notice; they were consolidated under a single reference. In his notices of appeal he said he had believed the liquidator was dealing with HMRC's correspondence, did not dispute the underlying debt, objected to the characterisation of the conduct as deliberate and concealed, and considered it unfair that the liability was assessed against him personally. By an application dated 18 June 2026 HMRC applied to strike out the appeal. The appellant was given the opportunity to respond but did not do so, and the application was decided on the papers.