TC09630 - [2025] UKFTT 01071 (TC)

If permission were to be given, HMRC would have to divert resources to prepare for the appeal and attend a hearing. Those resources could otherwise be used to ensure that other taxpayers are paying the correct amount of tax. Moreover, because of the passage of time, the Officers in question no longer work with HMRC. Even if they can be located and are willing to attend, the assessments in question were made in 2018 and 2019, and the passage of time (caused by the delay in applying for permission to appeal) is likely to have affected their memory of the events in question, and this may prejudice HMRC’s position.