The First-tier Tribunal allowed the appellant’s application to admit his late appeal against tax assessments, closure notices and penalty determinations, despite the appeal having been lodged over five months after the assessments and determinations.
HM Revenue and Customs (HMRC) issued tax assessments, closure notices and penalty determinations for the tax years 2007/08 to 2013/14 inclusive on 15 October 2015, and penalty determinations on 5 November 2015.
On 25 April 2016, a late appeal was submitted to the First-tier Tribunal (FTT) by the appellant’s agent. The appeal was therefore made over five months after the assessments and determinations of 15 October 2015 and 5 November 2015, and over four months after the statutory deadline of 30 days in which to lodge an appeal (TMA 1970, s 31A).
The appellant’s agent submitted that two letters dated 15 October 2015 sent by HMRC,
