TC09568 - [2025] UKFTT 00820 (TC)

It is our decision that the fair and just course is to allow the appellants’ applications for permission to bring appeals against the discovery assessments out of time, and we hereby grant them permission to do so.

It is our decision that the fair and just course is to reject the appellants’ applications for permission to bring appeals against the penalty notices out of time. And we hereby deny them permission to do so.

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.