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The discovery assessments
The discovery assessments
As is clear from the above, it is a statutory requirement under TMA s 31A(5) that a notice of appeal specify the grounds of appeal. The only document filed by Mr Cooke relating to the discovery assessments was a postponement application, and as Officer Fowler said, that did not constitute a notice of appeal. As a result, no appeals had been made to HMRC against the discovery assessments.
- 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