[2024] UKUT 00436 (TCC)
Upper Tribunal Tax and Chancery Chamber

[2024] UKUT 00436 (TCC)

Fecha: 19-Feb-2024

The application for permission to appeal to the UT

The application for permission to appeal to the UT

9.

By a decision dated 12 July 2024 (“the PTA Decision”), the FTT refused permission to appeal the FTT’s Decision to the UT on the grounds of appeal pursued by the Applicant. The Applicant renewed his application to the UT for permission to appeal in-time on 10 August 2024.

10.

I refused permission to appeal to the UT on the papers on 8 October 2024. The Applicant requested that permission be reconsidered at an oral hearing. I held a remote video hearing on 16 December 2024 at which the Applicant appeared assisted, as he was in the FTT, by his former accountant Mr Lorriman, acting as a McKenzie friend rather than as a representative.

11.

At my request during the hearing, the Applicant provided the nine page written speaking note, most of which he read out to me. During the hearing he also emailed the three further witness statements to which he referred to in the speaking note which he sought to admit as fresh evidence on the appeal to the UT (the statements not having been produced to the FTT). I permitted the Applicant to address at me length during the hearing (which lasted over two hours), repeating many of the points that were set out in writing in that speaking note.

12.

Subsequent to the hearing – on 16 December 2024 he emailed me further documents which I permitted him to present to me in support of his application.