Umar Hussain v The Commissioners for HMRC

Facts

The appellant, Mr Umar Hussain, sought to make a late appeal to the Tribunal against HMRC decisions contained in two view of the matter letters. The first, dated 18 March 2021, concluded that he was liable to £145,949 income tax and a £43,101 penalty, plus interest, for the tax years ending 5 April 2014 to 5 April 2017. The second, dated 24 May 2023, upheld an assessment for the year ending 5 April 2019 of £272,560 capital gains tax and a penalty of £181,252.40. His notice of appeal of 12 October 2023, which included the Late Appeal Application, was 908 days and 111 days late respectively. He relied on his daughter's illness and on being let down by his accountant. HMRC objected. Directions issued on 23 May 2024 required a list of documents and witness statements by 21 June 2024, which the appellant did not provide. After repeated extensions and requests for updates, the Tribunal issued unless orders, the third of which, dated 29 October 2025, required compliance by 28 November 2025. The appellant did not comply, and on 12 December 2025 the Tribunal confirmed that the Late Appeal Application had been automatically struck out. On 29 December 2025 he applied for reinstatement. Several applications to postpone the hearing were refused, and the application was heard on 23 September 2026, when the appellant appeared in person and gave oral evidence.