Permission refused to make a late appeal to the tribunal

The taxpayer appealed against penalties imposed for his failure to submit his 2014-15 tax return on time. He claimed he had reasonable excuse due to difficulties in moving home. However his appeal to the First-tier Tribunal was out of time – the appeal in relation to the most recent penalties was 986 days late and to the initial ones was 1 168 days late.

The tribunal judge said this was ‘serious and significant’. The taxpayer offered no explanation for the delay yet he must have been aware of the penalties months before he filed the appeals. The judge said HMRC was entitled to ‘some finality in properly administering the self assessment tax regime’ and the time limits existed to give that. She decided on balance that it would not be appropriate to extend the time limit and refused permission to appeal out of time.

However the judge went on to...