In H Armstrong v HMRC [2018] UKFTT 404 (18 July 2018) the FTT found that Ms Armstrong had not received a valid notice of penalty under Income and Corporation Taxes (Electronic Communications) Regulations SI 2003/282 (Ecomms regulations).
HMRC had sent a notice to deliver a return by electronic communication to Ms Armstrong’s secure mailbox. The notice required her to deliver a return by 31 January 2017. She did not file the return by the deadline and HMRC imposed a penalty on 7 February 2017 notice of which was again sent by electronic communication. Further penalties were subsequently issued for her continued failure. Ms Armstrong appealed against the penalties imposed her appeal was out of time and she applied for permission for a late appeal.
In relation to the late appeal application the FTT noted that the delay ‘while being serious and significant’ was not at...
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