Too late

The taxpayer applied to the First-tier Tribunal to allow a late appeal against a penalty of £45 604 imposed by HMRC for failure to report a capital gains tax liability.

The Revenue notified the penalty in May 2011. The taxpayer’s accountant requested a review but the fine was confirmed three months later with a note that an appeal would have to be lodged within 30 days.

The accountant wrote to the tax department in November 2011 saying he hoped to lodge an appeal within seven days. The delay was attributed to the taxpayer’s poor health.

The accountant told HMRC in January 2012 that he would submit the appeal shortly but was having problems contacting the taxpayer because of his health problems.

The Revenue said it would not object to a late appeal but the decision lay with the First-tier Tribunal.

The appeal was submitted in June 2012 and...