Countrywide Partners Ltd v Revenue and Customs (Penalties - whether the appellant had failed to comply with a "stop notice" imposed on the appellant by HMRC on 6 Dec 2022 under section s 236A FA 2014 such that the appellant is liable to a penalty under para 2(1) of schedule 35 FA 2014 - whether the appellant had a reasonable excuse for the breach) [2026] UKFTT 357 (TC) (04 March 2026)