Lyon v Revenue and Customs (Late appeal - Martland considered - length of delay - whether good reason for delay - whether late appeal appropriate in all the circumstances) [2025] UKFTT 920 (TC) (31 July 2025)

Parties

Procedural Posture

Tax Appeal (first Tier Tribunal) / Application for Permission to Make a Late Appeal

Legal Issues

1. 1 Whether the appellant should be granted permission to make a late appeal against a Personal Liability Notice for Class 1 National Insurance Contributions
2. 2 Whether the appellant provided a good reason for the delay in appealing
3. 3 Whether the June Letter constituted a valid and timeous appeal

Ratio Decidendi

The appellant failed to provide a good reason for a serious and significant delay in appealing the Personal Liability Notice. The June Letter was not proved to have been sent or received, and even if it had been, it did not constitute a valid appeal under the statutory grounds. The Tribunal found that the need for statutory time limits to be respected outweighed any prejudice to the appellant, and therefore refused permission for a late appeal.

Court Disposition

Application for permission to make a late appeal refused; appeal not admitted.