An application for permission to make a late appeal was granted after an earlier appeal sent by email bounced without the knowledge of the appellant and his accountant.
HM Revenue and Customs (HMRC) issued enquiry closure notices, discovery assessments and penalty assessments. An appeal was initially lodged with HMRC and later with the First-tier Tribunal (FTT).
The appellant subsequently withdrew his appeal because he was offered a statutory internal HMRC review of the original decision. On 19 January 2015, HMRC issued their review conclusion letter, which upheld the original decision.â¯
On 20 February 2015, the appellant’s accountant (Ms U) attempted to file an appeal with the tribunal by email.â¯However, there was no record that it was received by the
