Ian Milhill v The Commissioners for HMRC
All HMRC decisions were duly notified to Mr Milhill, either directly or via his authorised agent. The delays in appealing were serious and significant, with no good reason established. Reliance on advisers does not excuse non-compliance with statutory deadlines. Permission for late appeals is refused.
- Parties
- Appellant: Ian Milhill; Respondents: The Commissioners for His Majesty’s Revenue and Customs
- Jurisdiction
- England and Wales
- Judgment Date
- 08 January 2025
- Procedural Posture
- Tax Appeal / Application for Permission to Make Late Appeals
- Outcome
- Application for permission to make late appeals refused
- Legal Topics
- Late Appeals, Notification of Decisions, Reliance on Advisers, Statutory Time Limits, Penalties and Assessments
Case Brief
Summary, issues, holding and outcome
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Parties
Ian Milhill
Appellant
The Commissioners for His Majesty’s Revenue and Customs
Respondents
Procedural Posture
Tax Appeal / Application for Permission to Make Late Appeals
Legal Issues
- 1 Whether all HMRC decisions were duly notified to the taxpayer
- 2 Whether permission should be granted for late appeals against tax and penalty assessments
Ratio Decidendi
All HMRC decisions were duly notified to Mr Milhill, either directly or via his authorised agent. The delays in appealing were serious and significant, with no good reason established. Reliance on advisers does not excuse non-compliance with statutory deadlines. Permission for late appeals is refused.
Court Disposition
Application for permission to make late appeals refused
Orders
- Permission to appeal late is refused
- All HMRC decisions stand as notified
Full Case Text
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