Taxpayer applications for appeals to be ‘infinitely suspended and effectively cancelled’ due to HMRC’s actions and delays were dismissed by the First-tier Tribunal. 
 
The applicants (brothers aged 89 and 91) claimed tax relief on gifts of a company’s shares to charity, in which a 2003 valuation of the shares was in issue. Appeals by other taxpayers who had made gifts of the company’s shares were also before the First-tier Tribunal (FTT). Following a case management hearing, directions were issued under which, in the absence of a ‘lead’ case, the brothers’ appeals would proceed with, and be heard at the same time, as the other appeals. 
 
On 19 March 2019, one of the brothers (BA) wrote to the FTT objecting to the directions and requesting that the brothers’ appeal be ‘infinitely suspended and effectively cancelled’ on the grounds that