Conclusions
Overall conclusion if Martland applies
For the reasons set out above, we refused the appeal.
Applying the alternative test
Applying the alternative test, we considered if Mr Rahman had a reasonable excuse for failing to meet the 45 day deadline and gave notice after the end of that period without unreasonable delay after that excuse ceased. For the reasons set out in [25(2) to (4)] we found that he did not have a reasonable excuse for failing to meet the 45 day deadline.
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: 20th JUNE 2025
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