Mr Di Lellio’s diagnosis
Mr Di Lellio’s diagnosis
On 1 October 2018, Mr Di Lellio was diagnosed with “high risk prostate cancer”. The Tribunal was provided with a letter from his clinical consultant oncologist issued on that date, confirming the diagnosis. The oncologist also said that Mr Di Lellio “continues to be very active” working in his restaurant, and we find that to be a fact. No subsequent medical evidence was included in the Bundle.
- 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
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