Lloyd v Revenue and Customs (PROCEDURE - HMRC application to extend time for filing statement of case) [2025] UKFTT 563 (TC) (22 May 2025)

Lloyd v Revenue and Customs (PROCEDURE - HMRC application to extend time for filing statement of case) [2025] UKFTT 563 (TC) (22 May 2025)

The application for extension was made before the expiry of the permitted period, so it was not a relief from sanctions case. The delay was short, justified by the late provision of evidence and the need for further internal review. There was no prejudice to the appellant, and the interests of justice and the overriding objective required granting the extension.

Citation
[2025] UKFTT 563 (TC)
Parties
Appellant: Simon Lloyd; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
22 May 2025
Procedural Posture
Tax Appeal / Case Management Application for Extension of Time
Outcome
Application granted
Legal Topics
Extension of Time, Case Management, Statement of Case, Relief From Sanctions
Tax Law Civil Procedure Extension of Time Case Management Statement of Case Relief From Sanctions

Case Brief

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Parties

Simon Lloyd

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Case Management Application for Extension of Time

Legal Issues

  1. 1 Whether HMRC should be granted a further 14-day extension to file their statement of case
  2. 2 Whether the application is for relief from sanctions or a standard extension of time

Ratio Decidendi

The application for extension was made before the expiry of the permitted period, so it was not a relief from sanctions case. The delay was short, justified by the late provision of evidence and the need for further internal review. There was no prejudice to the appellant, and the interests of justice and the overriding objective required granting the extension.

Court Disposition

Application granted

Orders

  • HMRC granted a 14-day extension to file their statement of case.