Castle v Revenue & Customs (INCOME TAX/CORPORATION TAX : Appeal) [2018] UKFTT 526 (TC) (29 August 2018)

Castle v Revenue & Customs (INCOME TAX/CORPORATION TAX : Appeal) [2018] UKFTT 526 (TC) (29 August 2018)

Permission for late appeals was refused because the Appellant failed to engage with the Respondents for an unreasonably prolonged period without reasonable excuse, and the delay undermined the finality and certainty required by statutory time limits.

Citation
[2018] UKFTT 526 (TC)
Parties
Appellant: John Castle; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
29 August 2018
Procedural Posture
Income Tax/corporation Tax Appeal / Application for Permission to Make Late Appeals
Outcome
Permission to make late appeals refused.
Legal Topics
Late Appeals, Income Tax Assessments, Discovery Assessments, Procedural Time Limits
Tax Law Late Appeals Income Tax Assessments Discovery Assessments Procedural Time Limits

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Parties

John Castle

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Income Tax/corporation Tax Appeal / Application for Permission to Make Late Appeals

Legal Issues

  1. 1 Whether permission should be granted for late appeals against income tax and national insurance assessments issued over four years prior

Ratio Decidendi

Permission for late appeals was refused because the Appellant failed to engage with the Respondents for an unreasonably prolonged period without reasonable excuse, and the delay undermined the finality and certainty required by statutory time limits.

Court Disposition

Permission to make late appeals refused.

Orders

  • The relevant assessments are final and not subject to appeal.