In the First-tier Tribunal, Rebecca Sheldon acted on behalf of the Appellants, Universal Flooring (Contractors) Limited and Mark Mackley. This appeal concerned a penalty notice issued by HMRC on the 20th of March 2018 to the first Appellant, Universal Flooring (Contractors) Limited and a penalty liability notice issued on the same date to the second Appellant, Mark Mackley. Both the company and the director appealed against these notices. The Appellants liability under such notices was dependant, on whether VAT has been evaded by the company and if the director had behaved dishonestly. Rebecca successfully argued as to why he has not behaved dishonestly, leading to the court allowing this appeal. By way of his ratio decidendi, Judge Nigel Popplewell outlined 3 main reasons as to why the director’s behaviour was careless and reckless but not dishonest. For more information on this case, please view the judgment.