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B Nowroozi v HMRC

Appeal reinstated after over two years

In B Nowroozi v HMRC [2019] UKFTT 533 (12 August 2019) the FTT allowed the reinstatement of the taxpayer’s appeal over two years after it was struck out.

Mr Nowroozi had appealed against a CGT assessment on the ground that principal private residence relief applied to the sale of his property. The tribunal had issued a direction in December 2015 requesting compliance by 15 January 2016. On 27 January 2016 the tribunal had written to Mr Nowroozi’s accounting firm requiring a response within seven days. In the absence of any response the FTT had then issued an ‘unless letter’ to the accountants warning that if no reply was received within two weeks the appeal would be struck out. This letter was copied to Mr Nowroozi. In the absence of response to that final letter the tribunal had...

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