The Government always wins.  See the case below for an exceptionally harsh (on first read) penalty.  However, rules are rules.  The penalty represents only a small proportion of the actual profit the appellant made and with that sort of money,

An interesting case below that will no doubt be subject to an appeal by HMRC. Traditionally, the first £30,000 of a settlement agreement will be tax free. The amounts the footballers received in the case below is not mentioned but