Francis Bridgeman v The Commissioners for HMRC
Decision date: 7 May 2026
Neutral citation: [2026] UKFTT 679 (TC)
Overall AI summary confidence: high
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: high
This case concerns an application for permission to bring a 529‑day late appeal against HMRC’s 12 April 2024 review upholding a final closure notice for tax year 2013 (£16,891.75). The Tribunal applied the Martland three-stage test, accepted that the Appellant genuinely believed an 11 May 2024 email amounted to valid notice of appeal, and on balance granted permission to file the late appeal, ordering it consolidated with an existing in‑time appeal (TC/2024/01247).
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 indicates that where an in‑time communication falls short of formal notice requirements, a genuinely held and reasonable procedural misunderstanding can be a mitigating factor in the Martland balancing exercise, such that substantial delay may be excused if the applicant took timely steps in good faith, acted promptly once the defect was identified, and the respondent’s prejudice and the merits of the appeal do not decisively outweigh those factors.
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: low
The Tribunal remarked it would place limited weight on the Appellant’s prior profession as a solicitor where he denied specialist expertise in tax litigation, and noted that related ongoing litigation and forthcoming hearings can diminish practical prejudice from admitting a late appeal. These comments appear as observational guidance rather than binding reasoning.