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The taxpayer partnership applied under TMA 1970 s 49 in March 2012 to extend the time for appealing against amendments made by HMRC in closure notices issued in December 2008.
The partnership said it had asked a Revenue officer in a telephone conversation to be given permission to give notices of appeal and had been refused.
The business said it had never received the closure notices or any other letters sent by the taxman.
HMRC argued that a notice of appeal had to be given for the lateness of an appeal to be considered. The First-tier Tribunal said this was not the case.
In exercising its discretion to give permission for a late appeal the tribunal would give effect to the overriding objective in rule 2(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 SI 2009/273 to deal with cases fairly and justly.
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