TC09600 - [2025] UKFTT 00919 (TC)

Fecha: 03-Jul-2025

Decisions issued after 3 July 2020

Decisions issued after 3 July 2020

67.

The decisions made after 3 July 2020 were addressed to Mr Milhill in Grantham and copied to Haines Watts. There was no dispute that these letters had been properly addressed, prepaid and posted. In accordance with the Interpretation Act s 7; they were therefore deemed to have been delivered to Mr Milhill unless he proved the contrary.

68.

We took into account the following:

(1)

Mr Milhill did not say in his witness statement that he had not received any of the decisions.

(2)

His grounds of appeal, drafted by Ms Rahman, included the following statement (our emphasis) “the tax assessments and tax penalty assessment were issued in 2021, but unfortunately, the client does not have a copy at this time apart from what was informed in the statutory demand”. This is not the same as an assertion that Mr Milhill was not notified of the decisions.

(3)

Mr Milhill’s oral evidence was that he “did not remember” whether he had received the decisions, but that his normal practice was to pass tax correspondence on receipt to Ms Griffiths.

69.

We find that Mr Milhill has not proved that these decisions were not served on him, and they are thus deemed to have been duly notified. Furthermore, on the balance of probabilities, given Mr Milhill’s normal practice in relation to letters from HMRC, we find as a fact that he received those decisions and passed them to Ms Griffiths.