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Neutral Citation: [2025] UKFTT 00919 (TC)
Case Number: TC09600
FIRST-TIER TRIBUNAL
TAX CHAMBER
By remote video hearing
Appeal reference: TC/2024/01251
PROCEDURE – numerous HMRC decisions – tax and penalties totalling £875,623 – some decisions sent to accountant’s home – whether all decisions notified – held, yes – whether to give permission for late appeals – reliance on advisers – significant delays without good reason –- application refused
Heard on: 3 July 2025
Judgment date: 31 July 2025
Before
TRIBUNAL JUDGE ANNE REDSTON
MR SIMON BIRD
Between
IAN MILHILL
Appellant
and
THE COMMISSIONERS FOR
HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Ms Jesmin Rahman, of Tax Resolute Ltd, instructed by Mr Milhill
For the Respondents: Ms Maddie di Benedetto, Litigator of HM Revenue and Customs’ Solicitor’s Office
DECISION
- 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