Lalic v Revenue & Customs (INCOME TAX/CORPORATION TAX : Assessment/self-assessment) [2018] UKFTT 618 (TC) (15 October 2018)

Lalic v Revenue & Customs (INCOME TAX/CORPORATION TAX : Assessment/self-assessment) [2018] UKFTT 618 (TC) (15 October 2018)

The appellant failed to provide any reasonable excuse for the significant delay in appealing, and the interests of justice and finality in tax matters require adherence to statutory time limits. The tribunal's discretion to admit late appeals should only be exercised exceptionally, and there was no justification to do so in this case.

Citation
[2018] UKFTT 618 (TC)
Parties
Appellant: Michael Lalic; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
15 October 2018
Procedural Posture
Income Tax/corporation Tax Assessment/self Assessment / Application for Permission to Appeal Out of Time
Outcome
Application for permission to appeal out of time refused.
Legal Topics
Income Tax Assessment, Self Assessment Penalties, Late Appeal, Reasonable Excuse, Tribunal Procedure
Tax Law Income Tax Assessment Self Assessment Penalties Late Appeal Reasonable Excuse Tribunal Procedure

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Parties

Michael Lalic

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Income Tax/corporation Tax Assessment/self Assessment / Application for Permission to Appeal Out of Time

Legal Issues

  1. 1 Whether the appellant should be granted permission to appeal out of time against HMRC's assessments and penalties for 2011-12 and 2012-13
  2. 2 Whether the appellant had a reasonable excuse for the late appeal

Ratio Decidendi

The appellant failed to provide any reasonable excuse for the significant delay in appealing, and the interests of justice and finality in tax matters require adherence to statutory time limits. The tribunal's discretion to admit late appeals should only be exercised exceptionally, and there was no justification to do so in this case.

Court Disposition

Application for permission to appeal out of time refused.

Orders

  • The application for permission to appeal out of time is refused.