Ian Mihill v The Commissioners for HMRC

Facts

Ian Mihill applied to the First-tier Tribunal (Tax Chamber) for permission to make late appeals against various assessments and penalties issued by HMRC, totalling £875,623 excluding interest. The background lay in an enquiry conducted by Mrs McGuire of HMRC, who issued a closure notice and amendments for the 2014/15 return and a discovery assessment for 2015/16 on 2 March 2020, followed by correspondence about errors and a penalty for deliberate behaviour. Mr Mihill's accountants, Haines Watts, first responded in September 2020, citing illness affecting Mr Mihill and Ms Griffiths and bereavements suffered by Mr Mihill; further details followed in October 2020. HMRC issued a notice under Schedule 36 and a penalty for failure to comply, and on 19 May 2021 Mrs McGuire refused to accept the late appeals. The FTT found that all the decisions had been notified to Mr Mihill and, applying Martland v HMRC, refused permission for late appeals in a decision released on 31 July 2025. The FTT refused permission to appeal on all grounds in October 2025. Mr Mihill renewed his application to the Upper Tribunal, which Judge Zaman refused on the papers on 6 February 2026. He then applied for that refusal to be reconsidered at a hearing, held on 18 June 2026, at which he appeared in person, having been made bankrupt and no longer able to instruct counsel.