OP, park your ideas and embrace others pl.
For others, the glaring procedural impropriety is to be found with this statement in the NTO:
'The penalty charge must be paid not later than the last day of the period of 28 days beginning with the date of this Notice to Owner'
(their emphasis)
The regs require the following:
3) A notice to owner must, in addition to the matters required to be included in it under regulation 3(2) of the 2022 Appeals Regulations, state—
......l
(f)that the penalty charge, if not already paid, must be paid within “the payment period” as defined by regulation 3(2)(a) of the 2022 Appeals Regulations,
which define the 'payment period' as:
the period of 28 days beginning with the date on which the notice is served (“the payment period”).
They've only been doing this for 17 years this month, they'll get it right eventually..but whether in my lifetime I don't know!
