20U.K.A person may appeal against—
(a)a decision of HMRC that a penalty under paragraph 1 is payable by that person, or
(b)a decision of HMRC as to the amount of a penalty under paragraph 1 payable by the person.
20U.K.A person may appeal against—
(a)a decision of HMRC that a penalty under paragraph 1 is payable by that person, or
(b)a decision of HMRC as to the amount of a penalty under paragraph 1 payable by the person.