Application to make late appeals refused

In January 2019 HMRC issued about 70 individuals with notices under FA 2008 Sch 36 para 1 on the basis that they had each become administrators of different pension schemes. 

Each notice contained identical requirements for information relating to each scheme. The individuals each appointed the Independent Tax and Forensic Services LLP (ITFSL) as agent when dealing with HMRC and it appealed on their behalf. HMRC refused the appeals were refused and ITFSL requested statutory reviews which upheld the notices. 

The agent notified the appeals of more than 20 individuals to the First-tier Tribunal and these are under way. However the pension schemes of 42 the taxpayers had been wound up and with these ITFSL took a different approach embarking on lengthy correspondence with HMRC in an effort to resolve the appeals without recourse to the tribunal. 

Of these individuals ...