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88.—(1) An applicant or purported applicant may appeal to an appeal tribunal in a case where HMRC have failed to comply with regulation 87.
(2) The power of the appeal tribunal is limited to the power to direct HMRC, in a case where it is satisfied that HMRC have acted unreasonably, to consider the application, or purported application, as mentioned in regulation 87 within such further period as is specified by the tribunal.
(3) The appeal must be made within 30 days following the expiry of the 30 day period referred to in regulation 87.
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