W Lewis (TC5465)
Late notice of appeals
The taxpayer a barrister made late appeals against assessments for the years 2005-06 to 2007-08 and 2009-10 to 2011-12. HMRC was seeking a bankruptcy order against him but this was stayed pending the outcome of the appeals. The taxpayer said he was a ‘busy man’ had medical problems and did not have ‘time to focus’ on his tax affairs.
The First-tier Tribunal said the taxpayer had ‘no good reason’ for failing to submit appeals in time. He persistently filed late returns. The judge described him as an ‘intelligent man with a legal background’ so he must have realised he had to do something with the assessments and closure notice issued by HMRC.
There would be some prejudice to HMRC.
If the late appeals were accepted there would be some prejudice to HMRC in that it would result in extra work but the...
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