The injury of a company’s sole director was not a reasonable excuse to allow the admission of a late appeal against penalties for the late filing of a corporation tax return.
HM Revenue and Customs (HMRC) issued penalties for the late filing of its corporation tax self-assessment return for the accounting period ended 28 February 2018. The appellant failed to follow the correct procedure for its appeal and appealed directly to the First-tier Tribunal (FTT). An appeal was not filed with the FTT until 1 June 2020, meaning that the appeal was late. HMRC objected to the appeal on grounds of lateness.
The main issues for the FTT were: (a)â¯whether the appellant could show a reasonable excuse for the long delay in filing its notice of appeal; and if the appeal were permitted to proceed as a late appeal,