A taxpayer was refused permission to appeal against a First-tier Tribunal decision by the Upper Tribunal, as the applicant’s grounds of appeal did not raise arguably material errors of law in the First-tier Tribunal’s decision, and there was no other compelling reason to grant permission. 

The applicant applied to the First-tier Tribunal (FTT) for the closure of an enquiry by HM Revenue and Customs (HMRC) into her tax return for 2019/20. The FTT dismissed the applicant’s application. The FTT concluded that HMRC had not extended the deadline for the filing of the applicant’s online tax return to 28 February 2021 as HMRC had not made any conclusive statement that it was doing so. Thus, HMRC had validly opened its enquiry on 7 March 2022. The FTT further decided that TMA 1970, s 118 did not have the effect that, even if there had been an extension of time granted by HMRC, the applicant’s tax return for 2019/20 would have been