The FTT has refused permission for a late appeal, despite sympathising with the taxpayer’s circumstances (Manguiat v HMRC [2023] UKFTT 312 (TC)).
The FTT commented:
“We have taken account of the circumstances that weigh in Mr Manguiat’s favour, namely the good reason for the delay and the prejudice that would be caused to him by being unable to challenge the assessments. However, when assessing the circumstances in HMRC’s favour, Mr Manguiat’s negligible chances of succeeding on appeal must have decisive weight. It is not in the interests of justice, nor even in Mr Manguiat’s interests, for both parties to proceed to a further hearing at some date in the future, and expend time and effort in preparing for a case in which the outcome would be in little doubt. The same applies to the time and effort that would be involved for both parties in preparing for the strike-out application that HMRC have said they would make if we were to grant the application for a late appeal.”
https://www.bailii.org/uk/cases/UKFTT/TC/2023/TC08769.html
Related content from Claritax Books
In Tax Appeals – Law and Practice at the FTT, tax barrister Keith Gordon analyses some 500 precedents to show how the FTT rules are applied in practice, and how taxpayers may use the tribunal system for appealing against tax decisions.
