55(1)An appeal may be brought against—
(a)an amendment of a self-assessment return under paragraph 19 (amendment during enquiry to prevent loss of tax);
(b)an amendment made by a closure notice under paragraph 22;
(c)a discovery assessment;
(d)an assessment of a penalty under paragraph 42, 43 or 46;
(e)an amendment made by a closure notice under paragraph 53;
(f)an assessment made under paragraph 54.
(2)Any such appeal is to be brought by the filing member (“the appellant”).
(3)Notice of the appeal must be given to HMRC—
(a)in writing, and
(b)within 30 days after the specified date.
(4)“Specified date” means—
(a)in relation to an appeal under sub-paragraph (1)(a), the date on which the notice of amendment was issued;
(b)in relation to an appeal under sub-paragraph (1)(b) or (e), the date on which the closure notice was issued;
(c)in relation to an appeal under sub-paragraph (1)(c), (d) or (f), the date on which the notice of assessment was issued.
(5)The notice of appeal must specify the grounds of appeal.
(6)Notice may be given after the time limit in sub-paragraph (3)(b) if—
(a)HMRC agrees, or
(b)where HMRC does not agree, the tribunal gives permission.
(7)HMRC must agree to notice being given after the time limit if the appellant has requested in writing that HMRC do so and HMRC is satisfied—
(a)that there was a reasonable excuse for not giving the notice before the time limit, and
(b)that the request has been made without unreasonable delay.
(8)If a request of the kind mentioned in sub-paragraph (7) is made, HMRC must notify the appellant of whether or not HMRC agrees to the request.