(1) Where action for the recovery of any tax has been taken by means of the institution of proceedings in any court or the issue of a certificate under section 960L, as the case may be, the Appeal Commissioners shall not accept a late appeal in relation to the tax until such action has been completed.
(2) Where a late appeal is accepted following the completion of the action referred to in subsection (1), the appellant shall not be entitled to repayment of any sum paid or borne by the appellant in respect of the costs of any court proceedings or, as the case may be, of any fees or expenses charged by the county registrar or sheriff executing a certificate under section 960L.