Hammant v Revenue and Customs (Late Appeal - Marland Considered) [2025] UKFTT 244 (TC) (21 February 2025)

Hammant v Revenue and Customs (Late Appeal - Marland Considered) [2025] UKFTT 244 (TC) (21 February 2025)

The delay of 112 days in appealing was serious and significant. The reason for the delay was Mr Hammant's failure to check his personal tax account despite receiving email alerts. He had agreed to paperless communication and the penalties were properly notified. There was no good reason for the default, and the...

Source-derived case information.

Citation
[2025] UKFTT 244 (TC)
Parties
Appellant: Benjamin Hammant; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
21 February 2025
Procedural Posture
Tax Penalty Appeal (late Appeal Application) / Application for Permission to Appeal Out of Time
Outcome
Permission to appeal out of time refused
Legal Topics
Late Appeal, Self Assessment Tax Return, Paperless Communication, Statutory Time Limits, Penalty Notices
Tax Law Administrative Law Late Appeal Self Assessment Tax Return Paperless Communication Statutory Time Limits Penalty Notices

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Parties

Benjamin Hammant

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Penalty Appeal (late Appeal Application) / Application for Permission to Appeal Out of Time

Legal Issues

  1. 1 Whether permission should be granted for a late appeal against tax penalties
  2. 2 Whether the delay in appealing was serious and significant
  3. 3 Whether there was a good reason for the delay

Ratio Decidendi

The delay of 112 days in appealing was serious and significant. The reason for the delay was Mr Hammant's failure to check his personal tax account despite receiving email alerts. He had agreed to paperless communication and the penalties were properly notified. There was no good reason for the default, and the balance of prejudice and public interest in respecting statutory time limits justified refusing permission for a late appeal.

Court Disposition

Permission to appeal out of time refused

Orders

  • Application for permission to commence a late appeal is refused