The executor of the deceased’s estate did not show a reasonable excuse warranting an extension of the time limit to appeal against an inheritance tax determination covering a delay of three years, four months, 29 days after the appeal deadline. 

In January 2013, HM Revenue and Customs (HMRC) issued an initial notice of determination to the appellant as executor of a deceased individual (pursuant to IHTA 1984, s 221). The appellant appealed against that determination. Following a review, HMRC notified the appellant of this outcome by a letter dated 13 July 2015. 

The deadline for appealing against HMRC’s review conclusion was 12 August 2015. However, the appellant did not successfully lodge an appeal until 11 January 2019. The delay in lodging the appeal amounted to three years, four months, 29 days after the deadline of 12 August 2015. The sole issue for the First-tier Tribunal (FTT) was whether it should extend time to allow the