Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period) [2025] UKFTT 893 (TC) (02 July 2025)

Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period) [2025] UKFTT 893 (TC) (02 July 2025)

The appeal was late because no valid request for statutory review was made within the statutory or extended period. The Valentine's Day letter did not constitute a valid request for review. Reliance on an agent is not a good reason for the delay, and the circumstances do not justify granting permission for a late appeal.

Citation
[2025] UKFTT 893
Parties
Appellant: Daniel Fireman; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
02 July 2025
Procedural Posture
Income Tax Appeal / Application for Permission to Bring a Late Appeal Against a Final Closure Notice
Outcome
Application for permission to bring a late appeal rejected; permission denied.
Legal Topics
Income Tax, Statutory Review, Late Appeal, Closure Notice, Tribunal Procedure
Tax Law Income Tax Statutory Review Late Appeal Closure Notice Tribunal Procedure

Case Brief

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Parties

Daniel Fireman

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / Application for Permission to Bring a Late Appeal Against a Final Closure Notice

Legal Issues

  1. 1 Whether the appeal against the closure notice was late
  2. 2 Whether a valid request for a statutory review was made within the requisite time period
  3. 3 Whether permission should be granted for a late appeal

Ratio Decidendi

The appeal was late because no valid request for statutory review was made within the statutory or extended period. The Valentine's Day letter did not constitute a valid request for review. Reliance on an agent is not a good reason for the delay, and the circumstances do not justify granting permission for a late appeal.

Court Disposition

Application for permission to bring a late appeal rejected; permission denied.