Article 19

For rule 27(2) there shall be substituted—

“(2)

At the hearing of an evasion penalty appeal, or an appeal against a penalty imposed under section 114(2) of the Customs and Excise Management Act 1979^f1or section 22 or section 23 of the Hydrocarbon Oil Duties Act 1979^f2, the tribunal shall follow the same procedure as is set out in paragraph (1) of this rule for the hearing of an appeal or application, but as if there were substituted—

(a)

“the Commissioners” for “the appellant or applicant”;

(b)

“their” for “his” in sub-paragraphs (a), (c), (h) and (j);

(c)

“in opposition to” for “in support of” in sub-paragraphs (b), (c) and (d); and

(d)

“in support of” for “in opposition to” in sub-paragraphs (f), (g) and (h).”.