The taxpayer’s appeal relating to her self-assessment return was struck out as the First-tier Tribunal had no jurisdiction to consider the appeal in the absence of an appealable decision by HM Revenue and Customs. 

On 23 August 2018, the appellant submitted a self-assessment return for the tax year 2017/18. On 18 April 2019, the First-tier Tribunal (FTT) decision in Silver v Revenue and Customs [2019] UKFTT 263 (TC) was released. On 7 August 2019, HM Revenue and Customs (HMRC) issued a tax calculation, including a breakdown of HMRC’s calculation of the appellant’s top slicing relief (TSR). By letter dated 15 August 2019, the appellant queried HMRC’s TSR calculation and stated: “Can you please show the detailed calculations of the top slice relief of £8,778.80. In the meantime, please accept this letter as an appeal.”  

By letter dated 25 August 2019, the appellant provided her TSR calculations,