The appellant, Martin West, went to tribunal to ask for permission to make a late appeal concerning assessments and closure notices issued by HMRC in 2018, and penalties issued in 2017 and 2018, which totalled £49,613.41.

However, West waited more than 1,000 days after the statutory time limit of 30 days to file his notice of appeal, together with the application, which gave his appeal little chance.

On 22 January 2016, HMRC wrote to West asking for details about the year ended 5 April 2015, alongside bank statements, invoices and the company’s turnover. ABC Accounting, West’s accountants at the time, were also copied in.

Neither West nor ABC responded. On 16 November 2016, HMRC forwarded a Sch 36 Notice, requiring that the information and documents listed were provided – again, no information or documents were received.