Late appeal after original emailed notification blocked by tribunal firewall

In February 2015 the taxpayer’s accountant emailed an appeal against penalties to the First-tier Tribunal. There was no record that the tribunal received the email. This was perhaps because the email was more than 10MB in size and so rejected by the tribunal’s firewall. In July 2015 HMRC referred the debt to its debt management department. The adviser then contacted HMRC to say she had lodged an appeal and sent a copy of her email. HMRC’s firewall blocked this email also but the HMRC officer was alerted to this and told the adviser. She sent the email in four separate messages which were not blocked.

However neither the taxpayer not the adviser received further communication from HMRC or the tribunal until February 2019 when the debt management department told the taxpayer the debt had been released for collection.

The adviser emailed the tribunal but HMRC objected to the late...