TC09669 - [2025] UKFTT 01256 (TC)

The notice of appeal was submitted to the Tribunal late. It was submitted on 25 July 2024, appealing against a review conclusion letter that was issued on 5 June 2024.

HMRC do not object to the lateness of the appeal.

We also note that Mr Marshall had attempted to submit an in-time appeal on 4 July 2024 but had made a mistake as to the attachment to the notice of appeal and it had been rejected by the Tribunal on 19 July 2024. Therefore the late appeal was the re-submission of the original appeal with the right attachment. This was explained in the notice of appeal, as is required.

We also note that HMRC had, after the appeal was submitted, notified Mr Marshall that there had been an irregularity with the statutory review process and therefore the review letter received had in fact been erroneous.

Given the delay was short, the explanation was made clear and the respondents do not object, we decided to proceed to consider the substantive appeal.