TC09600 - [2025] UKFTT 00919 (TC)

The collection of the amounts due from Mr Milhill were referred to HMRC’s Debt Management team, which initiated bankruptcy proceedings. In September 2022, Mr Milhill was served with a schedule of costs relating to those proceedings.

On 14 November 2023, Mr Milhill’s new agent, Tax Resolute Ltd, filed a Notice of Appeal with the Tribunal; this was rejected on the basis that direct tax appeals had first to be made to HMRC. On 24 January 2024, Ms Rahman wrote to HMRC on behalf of Mr Milhill, saying:

“The Client is appealing against all tax and penalty assessment issued against Ian Milhill. We understand that there was the additional income tax liability for 2014/15 - £326,955.61 and 2016/17 for 104,209.40 and 2017/18 - £82,162.47 on the basis that it is unreasonable and excessive. The tax assessments were issued on 21/06/2021 for £128,136.73. There were also schedule 24 Penalties for £237,710.88 dated 18/06/2021 and £76,506.67 dated 17/09/2021 and consequential tax penalties i.e. late filing penalties and tax geared tax penalties, which we would like to be done under the cover of one appeal as all the issues are connected.”

On 24 January 2024, HMRC refused to admit those late appeals, and on 1 February 2024, Ms Rahman filed a new Notice of Appeal with the Tribunal, which included an application for permission to make late appeals. The grounds repeated the passage set out above.

Meanwhile, HMRC had commenced enforcement action against Mr Milhill, applying to the High Court for him to be declared bankrupt. A related hearing had been listed for 1 July 2025, but was adjourned pending the outcome of these proceedings.