TC09514 - [2025] UKFTT 00524 (TC)

No weight should be attached to the fact that the appellant is a litigant in person.

On merits, the appellant’s case is weak. Three of the four grounds set out in the notice of appeal are not within the jurisdiction of the tribunal. The allocation of quota to the relevant periods is irrelevant to the question of the correctness of the appealable decision. There is therefore little prejudice to the appellant in denying permission. On the other hand, there will be prejudice to HMRC in having to divert resources to this appeal which could be better used in dealing with appeals which have been brought on a timely basis.

If we were to allow the application, the litigation will be prolonged at greater cost to HMRC. Time limits set by Parliament should be respected.

He is a man of business and is not a lawyer. It is not surprising, therefore, that he did not fully understand which was the correct document that had to be uploaded onto the tribunal’s website in order to make a valid appeal.

During the relevant period, i.e. between January 2024 and July 2024, the business was extremely busy. Furthermore, he was suffering from sleep deprivation arising from the constant care and attention required by his son. He asked for leniency arising from this.

Once he had paid the safeguarding duty on 17 January 2024, he had taken his eye off the ball and relaxed. He did not appreciate the finer points of bringing the appeal. This is symptomatic of his unusual personal situation.