No appealable decision

The taxpayer submitted her 2017-18 tax return on paper before the deadline and claimed top slicing relief. In August 2019 HMRC issued a tax liability calculation which included a calculation of the taxpayer’s top slicing relief. The taxpayer wrote to HMRC querying its top slicing computation and providing her own which produced a lower liability. She also asked HMRC to treat the letter as an appeal.

HMRC sent her a calculation of the liability but this was after the deadline for the taxpayer to amend her self assessment had expired. In 2021 she made a protective appeal/overpayment relief claim but HMRC said she needed to provide more information. The taxpayer missed this reply although said the likelihood was that it had been overlooked due to her husband being unwell.

In January 2024 the taxpayer appealed to the First-tier Tribunal and in March 2024 ...