LINCOLN v Revenue & Customs (LATE APPEAL - Martland considered - length of delay is serious and significant)

LATE APPEAL - Martland considered - length of delay is serious and significant - no good reason for delay - in all the circumstances, extension of time not justified - application refused

For the Respondents: �� Bayo Randle of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

             The appellant has made an application to make a late appeal and HMRC has formally objected to that.� This hearing was listed purely to decide whether or not a late appeal could be made.

             There is another appeal by Ms Lincoln which also relates to Inheritance Tax and Mr Falzon with reference TC/2021/01180 and dated 24 March 2021. It relates to a Review Conclusion letter issued by HMRC on 15 January 202. That appeal was more than two months late but HMRC have not objected to the late submission of that appeal on the basis that at that time HMRC had implemented a Covid related policy not to object if an appeal was lodged within three months of the end of the 30-day appeal period.

             We had a Hearing Bundle extending to 558 pages and a Skeleton Argument from Mr Randle. In the course of the hearing Ms Lincoln lodged excerpts from other documents.