[214A Appeal against a section 208A penalty]

[214A  Appeal against a section 208A penalty]

[(1)     P may appeal against a decision of HMRC that a penalty is payable by P under section 208A.

(2)     P may appeal against a decision of HMRC as to the amount of a penalty payable by P under section 208A.

(3)     An appeal under subsection (1) may be

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