Michael Stefan Duma v The Commissioners for HMRC

Facts

HMRC issued Notices of Requirement ("NORs") to Intech Ventures Limited and to Mr Michael Stefan Duma, requiring security for PAYE and NICs. Both appealed to the First-tier Tribunal (Tax Chamber) against the notices. The FTT directed a preliminary hearing to determine three issues: whether the appeal had been brought in time by either or both appellants; if not, whether the appeal should nevertheless be admitted late; and what directions, if any, should be given to progress the substantive appeal to a hearing. Intech was wound up and did not participate. By a decision released on 26 November 2025 the FTT held that Mr Duma's appeal had not been brought in time, declined to admit it late, and concluded that no further directions were required. Mr Duma applied to the FTT for permission to appeal, which was refused on 19 February 2026. He renewed the application to the Upper Tribunal, where Judge Thomas Scott refused permission on the papers on 31 March 2026. Mr Duma requested an oral hearing to reconsider that refusal. The hearing took place remotely on 20 July 2026, Mr Duma being represented by Andrew Young of Counsel and HMRC by Joshua Carey of Counsel. The grounds originally advanced in March 2026 were no longer pursued, and a skeleton argument filed the working day before the hearing raised arguments not previously put to the Upper Tribunal.