A defendant (or, in Scotland, a defender) may appeal against a
penalty determined by an officer of the Board under TMA70/S100 or
by the Commissioners.
An appeal against a penalty determined by an officer of HMRC
is to the Commissioners.
An appeal against a penalty determined by the Commissioners
is to the High Court in England and Wales (and to the Court of
Session in Scotland). In Northern Ireland the relevant rules are
contained in Order 91, Rule 4, of the Rules of the Supreme Court
(Northern Ireland) 1980, a copy of which has been supplied to each
office in Northern Ireland.