![TC09630 - [2025] UKFTT 01071 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
The steps taken by the parties
The steps taken by the parties
It took some time during the hearing to establish the appeal position in relation to each of the matters encompassed by the Application, in part because of the way the documents were organised in the Bundle. However, when that exercise had been completed, Mr Sanders agreed with Ms Man that no appeals had been made, and thus that the Tribunal had no jurisdiction.
The parties then agreed the following steps and carried them out:
Mr Sanders made an application to HMRC to appeal all the decisions referred to in the Application, by sending an email to Ms Man;
Ms Man refused the appeal on behalf of HMRC by replying to Mr Sanders’s email; and
the Tribunal was copied on that correspondence.
It followed that the Tribunal then had the jurisdiction to hear Mr Di Lellio’s application to make late appeals. Both parties asked us to continue with the hearing and decide the Application.
- 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