In Romasave (Property Services) v HMRC [2015] UKUT 0254 (27 May 2015) the UT found that a taxpayer had not been notified of assessments sent to its solicitor and accountant.
The issue was whether late appeals should be allowed. This depended on whether Romasave’s solicitors which had received the assessments had authority to accept their service or notification. The UT noted that the mere fact that they were Romasave’s solicitors did not give them authority. Furthermore the scope of the solicitors’ letter of authority was limited to dealings with HMRC in relation to a demand for immediate payment. Lastly it could not be inferred from the request for correspondence sent by the solicitors to HMRC that they had the authority to receive assessments.
The same applied to Romasave’s accountants. The mere receipt of copies of the assessments followed by the carrying out of work...
