The returns were apparently saying how much they should have paid. The ideal defence would have been quoting Homer Simpson, "Everything looks bad if you remember it!"yes I'm sure you're right. But it just seems really odd that he paid not corporation tax or VAT whatsoever despite submitting returns. VAT is quarterly so they'll know very quickly if you're not paying it. Late payment penalties start very quickly and start escalating quickly - I'm struggling to see how he was left for 2 years to be submitting VAT returns, not paying anything and he's not being done for VAT fraud