Repeated non-compliance by the appellant’s accountant caused an earlier appeal to be struck out, which was followed by a new appeal against the same HMRC decision instead of a reinstatement application, and HMRC’s application for the appeal to be struck out was allowed as it would be an ‘abuse of process’ to allow the new appeal to continue.  

The appellant, a hairdresser, sold a property in Peckham in November 2015. HM Revenue and Customs (HMRC) was notified of the property sale via the Land Registry. The appellant had been sent a notice to file his self-assessment return for 2015/16, but he did not file the return until 8 February 2018; it included a capital gain relating to the sale of the property. In July 2018, HMRC opened an enquiry into the return. In August 2020, HMRC issued an enquiry closure notice, increasing the tax payable by £110,990. In April 2021, the appellant’s representative (WA), appealed to the