The term "neglect" in the Social Security Administration Act 1992 s.121C(1)(b) was to be interpreted on a subjective basis. Section 121C was penal in nature and an individual's mens rea formed an essential ingredient of assessing their liability for unpaid national insurance contributions under a personal liability notice.

FTT (Tax) (Judge Stephen Oliver QC (Chairman), Anne Redston) 19/12/2011
[2011] UKFTT 839 (TC)