TC09568 - [2025] UKFTT 00820 (TC)

This decision deals with applications (“the applications”) by the appellants for permission to bring late appeals against firstly discovery assessments visited on them pursuant to section 29 Taxes Management Act 1970 (“TMA”), and secondly penalties (“the penalty notices”) for failing to comply with information notices (“the information notices”) issued to them pursuant to the provisions of schedule 36 Finance Act 2008 (“schedule 36”).

The amounts to which they have been assessed by the discovery assessments are considerable. Mr Stenhouse has been assessed to additional income tax of £305,708. Mrs Stenhouse has been assessed to additional income tax of £141,931. The penalties amount to £13,700.

It is HMRC’s assertion that the appeals are between 68 months and 33 months late and there is no good reason for this delay. They therefore oppose the applications.

For the reasons given later in this decision we have allowed the applications in respect of the discovery assessments but rejected them for the penalty notices.