Background
In January 2007, HM Revenue and Customs (HMRC) issued tax returns to the appellant for the tax years 2001/02 to 2005/06. However, the appellant did not submit the returns by the due date.
HMRC subsequently made determinations for those years, based on an estimate of her tax liability. The appellant later filed tax returns for 2002/03 to 2004/05 inclusive. Following enquiries into those returns, HMRC made assessments, which displaced the figures in the appellant’s returns, and issued determinations up to and including 2008/09.
HMRC also issued various penalties and surcharges, in respect of the tax years 2001/02 to 2009/10 inclusive. The appellant appealed. The issues for the First-tier Tribunal (FTT) were: (a) the appellant’s application for her appeals against the penalties and surcharges to be admitted out of time; and (b) if admitted out of time, the
