Curtis v Revenue And Customs (INCOME TAX - procedure - application for strike out - jurisdiction) [2025] UKFTT 1605 (TC) (22 December 2025)

Curtis v Revenue And Customs (INCOME TAX - procedure - application for strike out - jurisdiction) [2025] UKFTT 1605 (TC) (22 December 2025)

Notice of appeal must be given to HMRC prior to notification to the Tribunal; the May 2023 appeals were not validly notified to HMRC before Tribunal notification and are struck out for lack of jurisdiction. The November 2023 appeals were validly notified to HMRC in time and are not struck out.

Citation
[2025] UKFTT 1605 (TC)
Parties
Appellant: Mark Curtis; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
22 December 2025
Procedural Posture
Income Tax Appeal / Application for Strike Out and Permission to Bring Late Appeal
Outcome
May 2023 appeals struck out for lack of jurisdiction; November 2023 appeals allowed to proceed.
Legal Topics
Income Tax, Jurisdiction, Appeal Procedure, Strike Out Applications, Late Appeals
Tax Law Administrative Law Income Tax Jurisdiction Appeal Procedure Strike Out Applications Late Appeals

Case Brief

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Parties

Mark Curtis

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / Application for Strike Out and Permission to Bring Late Appeal

Legal Issues

  1. 1 Whether notice of appeal must be given to HMRC before notifying the Tribunal
  2. 2 Whether the May 2023 appeals were validly notified to HMRC
  3. 3 Whether the November 2023 appeals were late and subject to strike out

Ratio Decidendi

Notice of appeal must be given to HMRC prior to notification to the Tribunal; the May 2023 appeals were not validly notified to HMRC before Tribunal notification and are struck out for lack of jurisdiction. The November 2023 appeals were validly notified to HMRC in time and are not struck out.

Court Disposition

May 2023 appeals struck out for lack of jurisdiction; November 2023 appeals allowed to proceed.

Orders

  • May 2023 appeals struck out under Rule 8(2) for lack of jurisdiction.
  • Application to strike out November 2023 appeals refused.