Paragraph 37
A person may appeal against—
(a)
a decision of HMRC that a penalty under paragraph 1 is payable by that person, or
(b)
a decision of HMRC as to the amount of a penalty under paragraph 1 payable by the person.
A person may appeal against—
a decision of HMRC that a penalty under paragraph 1 is payable by that person, or
a decision of HMRC as to the amount of a penalty under paragraph 1 payable by the person.