TC09602 - [2025] UKFTT 00930 (TC)

If Mr Gill’s reinstatement application does not succeed, the PLN will become final, and he will owe HMRC £1,825,818.08. He is also likely to face bankruptcy, as he told Officer King would be the position. Those are, however, the inevitable consequences of a person with few or no assets losing the opportunity to challenge an HMRC decision at the Tribunal, and I accord them little weight.

Mr Gill has serious physical health conditions and suffers from anxiety and depression. It is reasonable to assume that his health will worsen if the PLN becomes final as the result of losing this application. I accord that factor some weight.