In William Martland v HMRC [2018] UKUT178 the Upper tribunal refused permission for a late appeal against an excise duty assessment and penalties for wrongdoing totalling £34,201.
The facts of this case are of little interest as it concerned beer excise duty, the interesting part is that the Upper Tribunal took the time to set out helpful guidance on the principles for dealing with a late appeal which can be applied to all tax related appeals.
See our guide for subscribers for full details and full back ground on: Late appeals
Comment
The principles set out in Martland were closely followed in The Personal representative of Mark Collins v HMRC [2018] TC06597 where the First Tier tribunal allowed executors to appeal discovery assessments issued to the deceased which were nearly four years late.
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