Conclusions
DECISION
I allow the application.
RIGHT TO APPLY FOR PERMISSION TO APPEAL
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 22nd May 2025
- 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
![TC09527 - [2025] UKFTT 00563 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png)