Adrian Vlad and Ion Grab v The Commissioners for HMRC
Decision date: 22 October 2026
Neutral citation: [2026] UKFTT 1487 (TC)
Overall AI summary confidence: medium
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: medium
This case concerned applications by Adrian Vlad and Ion Grab for permission to admit late appeals against HMRC decisions. The Tribunal applied the Martland test, found substantial unexplained delays, held that although their shared accountant misled them the appellants should have taken independent steps once warning signs emerged (March 2022 for Grab, July 2022 for Vlad), and refused permission to admit the late appeals. The appeals were dismissed.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
The Tribunal treated failings of a taxpayer’s adviser as generally attributable to the taxpayer for the purpose of assessing late appeals, but recognised exceptions may exist; an appellant must show they acted as a reasonable taxpayer would once warning signs appeared. Long, unexplained delay and the public interest in compliance with statutory time limits are powerful factors against admitting late appeals.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal observed that factors such as health problems and difficulty in finding new advisers may be relevant to explaining delay but may not suffice to excuse extensive delay. It also noted the underlying merits were treated neutrally because of insufficient material on them.