Taxpayers’ appeals against closure notices were struck out for failure to comply in time with a direction requiring them to serve replies setting out further and better particulars of their cases. The non-compliance was serious and it was clear that the taxpayers did not truly intend to take the appeals to a hearing. That they had been engaged in negotiations to try to settle the appeals was not a good reason for non-compliance. Parties could not be permitted to decide for themselves whether and when to comply with the tribunal’s directions.
