Mr Milhill’s business and the addresses
Mr Milhill’s business and the addresses
Mr Milhill initially ran a call centre business via a number of companies and partnerships, working with a Mr Milanesi; that relationship broke down in 2016-17. The affairs of the businesses were dealt with by Haines Watts, a firm of Chartered Accountants, who were also instructed in relation to Mr Milhill’s personal tax. At all relevant times, Ms Jackie Griffiths, an accountant, acted as Mr Milhill’s finance manager. Mr Milhill said that he had set up these arrangements so that Ms Griffiths and Haines Watts between them dealt with all his tax affairs.
Mr Milhill had told HMRC he lived at an address in Nottingham, and until 3 July 2020, HMRC addressed all correspondence to him at that address. However, it was in fact Ms Griffiths’ home address. Mr Milhill provided that address to HMRC because he travelled frequently and because Ms Griffiths dealt with his financial and tax affairs.
On 3 July 2020, prior to commencing enforcement proceedings, HMRC checked the address they had been given by Mr Milhill, and realised it was not his home address. From that date onwards, all HMRC correspondence was addressed to Mr Milhill at his home address in Grantham.
- 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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