In S Sood v HMRC [2019] UKFTT 368 (11 June 2019) the FTT found that HMRC’s acceptance of a late appeal it now opposed could be inferred from a letter it had sent to the taxpayer.
Mr Sood applied to the tribunal for permission to make late appeals to HMRC against amendments to his self-assessment tax returns and penalty determinations issued in respect of each of the tax years 2008/09 to 2013/14. HMRC opposed the application on the basis that Mr Sood had failed to prosecute his appeal with reasonable diligence in that the appeal was over two years’ late.
On 29 April 2016 Mr Sood sent a letter to HMRC objecting to the penalties that had been issued to him covering the years 2008/09 to 2013/14. On 27 June 2016 HMRC responded to Mr Sood by letter. The FTT found that Mr Sood’s letter of April...
