Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period)
Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period) [2025] UKFTT 893 (TC) (02 July 2025)
The appeal was late because no valid or timely request for statutory review was made; the Valentine's Day letter did not constitute such a request when read objectively. Even if HMRC extended the deadline, the letter's content was insufficient. Reliance on an agent and confusion caused by HMRC's correspondence do not constitute good reasons for the delay. The statutory time limits must be respected, and permission for a late appeal is not justified on the facts.
Source excerpt
- Income tax
- Statutory review
- Appeal deadlines
- Late appeal
- Closure notice
- Section 49 tma