Diane Stoney v The Commissioners for HMRC

Diane Stoney v The Commissioners for HMRC

The Tribunal found that although the delay was serious and significant, the Appellant’s lack of understanding, personal circumstances, and reasonable actions in seeking assistance constituted a good reason for the delay. The prejudice to the Appellant in refusing the application outweighed the prejudice to HMRC, and...

Source-derived case information.

Parties
Appellant: Daine Stoney; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
07 November 2025
Procedural Posture
Tax Appeal / Application for Permission to Make a Late Appeal
Outcome
Application granted
Legal Topics
Late Appeal, Enterprise Investment Scheme (eis), Statutory Time Limits, Fraudulent Tax Claims, Self Assessment, Procedural Fairness
Tax Law Administrative Law Late Appeal Enterprise Investment Scheme (eis) Statutory Time Limits Fraudulent Tax Claims Self Assessment Procedural Fairness

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 13 Party arguments 2 Amounts and remedies 4
Sign in to unlock

Parties

Daine Stoney

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Permission to Make a Late Appeal

Legal Issues

  1. 1 Whether the Appellant should be granted permission to bring a late appeal against HMRC assessments and closure notices
  2. 2 Whether there was a good reason for the delay in appealing
  3. 3 Whether the interests of justice and fairness require the application to be allowed

Ratio Decidendi

The Tribunal found that although the delay was serious and significant, the Appellant’s lack of understanding, personal circumstances, and reasonable actions in seeking assistance constituted a good reason for the delay. The prejudice to the Appellant in refusing the application outweighed the prejudice to HMRC, and the interests of justice and fairness required that permission to bring a late appeal be granted.

Court Disposition

Application granted

Orders

  • Permission is granted to bring a late appeal.