Serious delay for late appeal was not justified

In January 2020 HMRC issued tax assessments to the taxpayer. Her agent notified appeals in December 2020 which HMRC refused to accept. The taxpayer applied to the First-tier Tribunal for permission to make late appeals.

The tribunal said first that the delay in appealing was almost ten months and this was ‘serious and significant’. It went on to consider the reasons for the failure to comply with the time limit. The tribunal noted that the taxpayer’s mother had died in autumn 2019 and the taxpayer had found it very difficult coping with ‘any matters’ for some time after that.

However the tribunal decided the evident did not show there was any good reason for the delay. On the fact that HMRC did not provide copies of the assessments or the debt recovery correspondence to the taxpayer’s agent the tribunal said there was no requirement for HMRC to copy...