Notes:
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PROCEDURE – application for late notice of appeal in the case of a number of income tax-related assessments and penalty determinations and two VAT-related penalty determinations – after taking into account, in each case, the extent of the delay in giving notice of appeal, the reasons for the delay and the other factors relevant to the exercise of the First-tier Tribunal’s discretion in this regard in accordance with applicable prior case law, it would not be appropriate for consent to the late notice to be given – accordingly, application dismissed |