An appeal purportedly by the taxpayer was found not to have been made on time, and permission to make a late appeal was refused.  

On 25 September 2019, HM Revenue and Customs (HMRC) sent an opening letter to the appellant informing him they had received information indicating he had made property purchases and sales that had not been recorded on his tax returns. HMRC’s letter formally opened checks into self-assessment returns for the tax years 2007/08, 2010/11, 2012/13, 2014/15 and 2015/16, and requested a series of documents and information. The letter was also shared with the appellant’s agent (FN).  

On 2 October 2019, FN called the officer to acknowledge receipt of the enquiry letter. Following a request for an extension to respond to the information request, HMRC issued an information notice on 5 November 2019, which gave a further 30 days for compliance. On 20 July 2020, HMRC issued discovery assessments for the