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Other Tribunal users
Other Tribunal users
If the Application were to be allowed, organising the relate appeals will take the time of tribunal staff, and the historic nature of the issues means that it is likely to take longer than if the appeals had been made by the statutory time limits. That time would otherwise be spent on the appeals of other Tribunal users, who have complied with the statutory requirements.
- 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