Izzet v Revenue & Customs (INCOME TAX/CORPORATION TAX : Appeal) [2018] UKFTT 642 (TC) (31 October 2018)

Izzet v Revenue & Customs (INCOME TAX/CORPORATION TAX : Appeal) [2018] UKFTT 642 (TC) (31 October 2018)

Permission is granted for the appellant to proceed with a late appeal against the closure notice for the tax year ending 5 April 2013, as the reasons for delay were reasonable and the respondent consented. Claims for interest relief for earlier years were out of time and not permitted.

Citation
[2018] UKFTT 642 (TC)
Parties
Appellant: Taskin Izzet; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
31 October 2018
Procedural Posture
Income Tax/corporation Tax Appeal / Application for Permission to Appeal Late Against a Closure Notice
Outcome
Permission to appeal late against the closure notice for the tax year ending 5 April 2013 is granted.
Legal Topics
Income Tax, Corporation Tax, Late Appeal, Closure Notice, Interest Relief, Reasonable Excuse
Tax Law Income Tax Corporation Tax Late Appeal Closure Notice Interest Relief Reasonable Excuse

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Parties

Taskin Izzet

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Income Tax/corporation Tax Appeal / Application for Permission to Appeal Late Against a Closure Notice

Legal Issues

  1. 1 Whether permission should be granted for a late appeal against a closure notice for the tax year ending 5 April 2013
  2. 2 Whether claims for interest relief for certain tax years were made within statutory time limits

Ratio Decidendi

Permission is granted for the appellant to proceed with a late appeal against the closure notice for the tax year ending 5 April 2013, as the reasons for delay were reasonable and the respondent consented. Claims for interest relief for earlier years were out of time and not permitted.

Court Disposition

Permission to appeal late against the closure notice for the tax year ending 5 April 2013 is granted.

Orders

  • The appellant may proceed with the appeal against the closure notice for the tax year ending 5 April 2013 despite the late notice.