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The first Martland stage: the delays
The first Martland stage: the delays
The first stage is to establish the length of the delay and whether it is serious and/or significant.
It was common ground that TMA s 31A required Mr Di Lellio to appeal the assessments within 30 days, but they were made on 21 August 2025, the day of this hearing. The appeals against the discovery assessments were thus over seven years late and all other appeals were over six years late.
Although Mr Sanders submitted that the delays were not serious and significant, we have no hesitation in agreeing with Ms Man that, in the context of an appeal right that was required to be exercised in 30 days, all the delays were both serious and significant.
- 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