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LATE APPEAL - Martland and Katib considered - length of delay serious and significant - whether good reason for delay - no - whether late appeal appropriate in all the circumstances - no - application refused - appeal not admitted
For the Appellant:�������� Nigel Ginniff, counsel, instructed by Cobham Murphy PHD, accountants
For the Respondents: �� Christine Cowan, litigator of HM Revenue and Customs� Solicitor�s Office
             The documents to which we were referred were an HMRC hearing bundle of 65 pages, an Appellant�s hearing bundle of 68 pages, an authorities bundle of 106 pages, Mr Ginniff�s written submissions on behalf of Mrs Green of 7 pages and HMRC�s submissions of 18 pages.� The Appellant�s hearing bundle included witness statements from Mrs Green, Mr Green and Mr Russell.
              Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� As such, the hearing was held in public.
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