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Notable Cases

The members of Cannon Chambers relish representing their clients in the courts and tribunals and fighting their client’s corner whenever mediation is unsuccessful or a settlement is not possible. The following selection of their recent cases gives you a flavour of their work as advocates.

MARIE GUERLAIN-DESAI V HMRC TC/2022/13097

This was an application by HMRC for an extension of time in which to file their Statement of Case 64 days late. The FTT recited the familiar three-stage test in Martland [2018] UKUT 178 (TCC) for considering an application for an extension of time, i.e., (1) establish the length of the…

BROSCH & BROSCH V HMRC TC/2020/01784

This was a decision on a “knock-out” point about whether discovery assessments were invalidated by the level of assumed disclosure given to HMRC by the appellants in relation to their use of Stamp Duty Land Tax avoidance schemes. The FTT held that while the information provided might have prompted the…

SMITH AND CORBETT V HMRC TC/2021/00047

This was a successful appeal by the taxpayers involving the transfer of goodwill by two IFAs to an LLP. HMRC had assessed the taxpayers to income tax on what HMRC said had been a distribution to them by their IFA company when the goodwill in question was credited to their…

JONATHAN RALPH V HMRC TC/2022/13513

This decision concerns a claim for multiple dwellings relief and is concerned (1) with the extent of the facilities required for the preparation of food in order for a building to be a dwelling and, alternatively, (2) whether the annex in question was in the process of being adapted for use…

L-L-O CONTRACTING LTD AND OTHERS v HMRC TC/2022/01346

This decision concerns taxpayers who failed to make claims for multiple dwellings relief in the 12 months allowed for making such claims and who, therefore, submitted claims for overpayment relief under para 34, Sch 10 FA 2003. There are Cases in the rules governing the relief that can block such…

SANGEETA MODHA V HMRC

This was an appeal about mixed residential and non-residential property and whether an 8-acre field that sloped away at the bottom end of a large garden and paddock was a part of the “grounds” of the dwelling and as such, liable to SDLT at the rates in Table A. The…

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