No prejudice to taxpayer to extend time limit

The taxpayer submitted a notice of appeal to the First-tier Tribunal against closure notices and a discovery assessment. On 25 October 2024 the tribunal directed HMRC to provide its statement of case within 60 days of that date. In December 2024 the taxpayer confirmed that he agreed to extending the deadline for HMRC’s statement to 22 February 2025. However due to complications HMRC applied to extend the date to 10 March 2025 and sent its statement of case to the taxpayer and tribunal on 4 March. The taxpayer objected to this extension.

At the tribunal hearing HMRC said it had made its extension application on 21 February before the expiry of the 22 February deadline so it was made in time.

The tribunal said it was ‘wholly appropriate’ that HMRC sought a short extension to be able to submit its statement of case. There...