TC09531 - [2025] UKFTT 00567 (TC)

This decision is concerned with whether the appellants are entitled to appeal late in respect of penalty assessments (raised on Ms Adeosun) and a personal liability notice (“PLN”) (raised on Nissi N Nissi Ltd (“NNN”)) in circumstances where the underlying VAT assessments are the subject of an in-time appeal to the Tribunal.

We were referred in the hearing to a hearing bundle.Ms Adeosun, for herself and as a director of NNN provided a short witness statement and gave evidence in the hearing. Mr Auchterlonie, an officer of HMRC, also provided a witness statement and gave evidence. Mr Auchterlonie investigated the VAT repayment claims which led to the VAT assessments, penalties and PLN.

The burden of proof in this matter is on the appellants.

We find the facts in this appeal as set out below.