0 h 24 min, 24 nov 2011 ans - Following a phone call from HMRC, Saffrey Champness emailed RFC officials with a summary of discussions. The email confirms that an application to a Tribunal for leave to appeal the determinations of 20 May 2011 had been progressed, although no decision had been forthcoming. HMRC confirmed their reasons for issuing out of time determinations on fraud or negligence grounds.

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It was noted that HMRC had described Ian McMillan, MIH Tax advisor, as a liar. Saffrey Champness also noted that, if HMRC could justify the extended time limits, they “have no fundamental position with regard to the late appeals because we have no material argument that the assessments themselves are incorrect.”

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