SolvedSAOG22500 | Appeals: Notifying the tribunal
From HM Revenue & Customs · Senior Accounting Officer Guidance
All tribunal appeals against penalty assessments made under the Senior Accounting Officer (SAO) provisions will be to the First Tier Tribunal.
It is for the person, not HMRC, to notify the appeal to the tribunal, see ARTG8200+.
The tribunal can decide whether to confirm or cancel the penalty.