TC09600 - [2025] UKFTT 00919 (TC)

Mr Milhill’s Notice of Appeal to the Tribunal, filed by Ms Rahman, began by saying that it encompassed “all tax and penalty assessments issued against Ian Milhill”, and continued by referring to (a) three of the closure notices and related amendments; (b) the Sch 24 penalties; unspecified late filing penalties, and (c) what were described as “tax geared tax penalties”. Ms Rahman told us this was a reference to late payment penalties.

We pointed out that there was no reference in the Notice of Appeal to (a) the discovery assessment for 2015-16; (b) the closure notices and related amendments for 2018-19, or (c) the Sch 36 penalties. Ms Rahman responded by referring to the opening words, which referred to “all tax and penalty assessment issued against Ian Milhill”.

We expressed some concern about the lack of specificity, but on behalf of HMRC, Ms di Benedetto said HMRC accepted that the Notice of Appeal did encompass the discovery assessment; the closure notice and related amendment for 2018-19; the Sch 36 penalties and those late payment penalties for which related documents had been included in the Bundle, namely those for 2014-15 and 2016-17, and we proceeded on that basis.