Failure to comply with an ‘unless order’

The taxpayer’s appeal concerned income tax assessments for the years 1996-97 to 2011-12 with the tax at stake about £942 131. HMRC considered that the taxpayer was liable to tax on undeclared income and gains but he claimed there was no UK liability owing because he had an Irish domicile.

The taxpayer appealed to the First-tier Tribunal in 2017. However due to various failures by the taxpayer to meet deadlines set by the tribunal on 25 September 2020 a tribunal judge issued an order that unless the taxpayer provided specified information by 15 October the appeals ‘may be struck out without further reference to the parties’.

The taxpayer failed to provide all of the information so in November 2020 a different judge issued a second unless order which stated that if the notice was not complied with the appeals would be struck...