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- Heading
- BACKGROUND FACTS
- RULE 2
- DISCUSSION
- In the alternative, if this is a relief from sanctions case, the principles are set out in the case of William Martland v HMRC [2018] UKUT 178 (“ Martland ”)
- Accordingly, in HMRC’s view a further extension was required. The application was made on 21 February 2025
- He also wants clarity on the current timetable for this appeal
- Conclusions