Application to this case
Application to this case
As is clear from the legislation set out at §56 above, all the relevant provisions required that Mr Milhill was notified before time could start to run for the purposes of an appeal.
We first considered whether we had sufficient evidence to decide that issue, and decided that we had: the Bundle contained 300 pages of correspondence between the parties and Mr Milhill had provided a witness statement as well as giving further detailed oral evidence.
We thus moved on to consider the decisions themselves, beginning with the least contentious: those issued after 3 July 2020, the date when HMRC changed Mr Milhill’s address on their system from that of Ms Griffiths to his own home.
- Heading
- Introduction
- The matters before the Tribunal
- The evidence
- Mr Milhill’s business and the addresses
- Late filing penalties
- The 2014-15 tax year
- The 2015-16 tax year
- The subsequent correspondence and assessments
- The appeals and applications, and the bankruptcy petition
- Mr Milhill’s mental health
- Mr Milhill’s physical health
- Ms Griffith’s health
- ISSUE 1: WHETHER MR MILHILL WAS NOTIFIED
- The Law
- The legislation under which the decisions were made
- The Interpretation Act
- The UT judgment in Websons
- Application to this case
- Decisions issued after 3 July 2020
- Decisions copied to Mr Milhill on 9 July 2020
- Decisions sent to Ms Griffiths
- ISSUE 2: WHETHER TO GIVE PERMISSION
- The time limits
- The Case Law
- The length of the delays
- Serious and/or significant?
- Mr Milhill’s health?
- Conclusions
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