Richard Alderson v The Commissioners for HMRC

Facts

The appellant, Mr Richard Alderson, held the licence for the Wheatsheaf Inn. On 11 May 2023 HMRC issued him two notices of assessment under paragraph 9 of Schedule 16 to the Finance Act 2020 totalling £80,564.44, on the basis that he had received Coronavirus Job Retention Scheme payments to which he was not entitled; on review, by conclusion letter dated 11 January 2024, the assessments were upheld but varied to £76,538.17. He appealed on 5 February 2024, acting in person. The Tribunal issued case management directions on 2 June 2025 requiring a list of documents by 18 July 2025, witness statements by 15 August 2025 and listing information by 29 August 2025. The appellant provided none of these, and did not respond within 14 days to a Tribunal letter of 30 July 2025, though he sent a long email on 15 August 2025 explaining that the brewery had cleared the premises after he was imprisoned, leaving him without employee records. On 26 September 2025 the Tribunal issued an unless order requiring, by 10 October 2025, written confirmation that he intended to proceed and compliance with Directions 1 to 3. Nothing was filed, and the appeal was automatically struck out. He applied for reinstatement on 23 October 2025, saying the emails had gone to his junk folder.