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Heading
Neutral Citation: [2025] UKFTT 01071 (TC)
Case Number: TC09630
FIRST-TIER TRIBUNAL
TAX CHAMBER
By remote video hearing
Appeal reference: TC/2024/00443
PROCEDURE –application for permission to make late appeal – Martland and Medpro considered – application refused
Heard on: 21 August 2025
Judgment date: 4 September 2025
Before
TRIBUNAL JUDGE ANNE REDSTON
MS HANNAH DEIGHTON
Between
REMIGLIO DI LELLIO
Appellant
and
THE COMMISSIONERS FOR
HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Mr Peter Sanders, of Thomas Cooke & Co, accountants
For the Respondents: Ms Fiona Man, Litigator of HM Revenue and Customs’ Solicitor’s Office
DECISION
- Heading
- Introduction and Summary
- The Evidence
- Findings of fact
- Tax years 2011-12 and 2012-13: assessments
- Tax years 2013-14 to 2015-16: assessments
- The Form
- Mr Di Lellio’s diagnosis
- Penalties for inaccuracies
- PLNs
- Subsequent events including bankruptcy proceedings
- Jurisdiction of the Tribunal
- The legislation about appeals
- The discovery assessments
- The closure notice amendments
- The steps taken by the parties
- The timing of the Application
- The Case Law
- The first Martland stage: the delays
- The second Marland stage: reasons for delays
- Reliance on advisers
- The need for time limits to be respected
- Merits
- Other prejudice to Mr Di Lellio
- Prejudice to HMRC
- Other Tribunal users
- Conclusions