David, I assume from your post that you did an option sub-sale scheme and if so, the fact that your transaction was before the retrospective closure of the scheme from March 2012 means that an appeal is a possibility. You should however weigh up the pros and cons before doing so. It will be interesting to see if HMRC issue the new “follower notices” and “accelerated payment notices” in respect of these schemes even in the absence of clear authority to do so.