TC09602 - [2025] UKFTT 00930 (TC)

In Chappell,the UT held that in reinstatement applications, the Tribunal should “generally take no account of the strength of the applicant’s case” unless that case was “unanswerable”. This is a PLN, where the burden rests on HMRC; Mr Gill appealed on the basis that he had not acted deliberately, and Ms Goldring did not submit that HMRC’s case was “unanswerable”. I have thus not taken the merits into account in my assessment of the circumstances.