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 or timely request for statutory review was made; the Valentine's Day letter did not constitute such a request when read objectively. Even if HMRC extended the deadline, the letter's content was insufficient. Reliance on an agent and confusion caused by HMRC's correspondence do not constitute good reasons for the delay. The statutory time limits must be respected, and permission for a late appeal is not justified on the facts.

Citation
[2025] UKFTT 893 (TC)
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, Appeal Deadlines, Late Appeal, Closure Notice, Section 49 TMA, Section 54 TMA
Tax Law Income Tax Statutory Review Appeal Deadlines Late Appeal Closure Notice Section 49 TMA Section 54 TMA

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 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 or timely request for statutory review was made; the Valentine's Day letter did not constitute such a request when read objectively. Even if HMRC extended the deadline, the letter's content was insufficient. Reliance on an agent and confusion caused by HMRC's correspondence do not constitute good reasons for the delay. The statutory time limits must be respected, and permission for a late appeal is not justified on the facts.

Court Disposition

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