Customs & Excise have been able to do this for years. It used to be one of the key defining differences between them and the Inland Revenue. If the IR had a court case go against them, they put up with it. But if C&E had a tribunal case go against them, they just whacked out another Statutory Instrument to reverse the decision.

It affected the nature of the department as a result; much more draconian. HMIT wouldn't bankrupt a taxpayer for non-payment of taxes. But C&E would wind up a business for non-payment of VAT, even if it was an honest mistake.

I wouldn't like to see the power given out to all government departments. :-(