Commentary

I11.312 Extension of time for appealing

IHT, trusts and estates

I11.312 Extension of time for appealing

I11.312 Extension of time for appealing

A notice of appeal may be given after the 30-day time limit has expired if HMRC agree or, if HMRC do not agree, the Tribunal (being the First-tier Tribunal) gives permission1.

HMRC must agree to a notice being given out of time provided that three conditions are satisfied2, namely:

  1.  

    •     The appellant makes a written request of HMRC to agree to the notice being given3

  2.  

    •     HMRC are satisfied that there is a reasonable excuse for the appellant not having given the notice of appeal before the time limit expired4

  3.  

    •     HMRC are satisfied that

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