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.
ALEXANDER CLARK AND REBECCA CLARK V HMRC TC/2023/00127
In this appeal about whether there were two separate dwellings at the property for the purpose of Multiple Dwellings Relief, the First-tier Tax Tribunal said that insufficient degrees of separation and privacy and security together with the status of the common utilities meant that the two dwellings could not each be...SUTERWALLA V HMRC [2024] UKUT 00188 (TCC)
This was HMRC's unsuccessful appeal to the Upper Tribunal against the FTT's decision that a paddock was not part of the grounds of a dwelling house for SDLT mixed-use purposes. In relation to HMRC's challenge, the UT said: "41. Mr Cannon submitted that HMRC’s challenges in this ground were ‘island...DAVIS and GUILBERT V HMRC
This was a successful appeal by the taxpayers involving an uninhabitable dwelling they had purchased in London SW3 in 2020. They said that the dwelling was uninhabitable because of several defects which rendered the property potentially dangerous but HMRC did not accept that the property was uninhabitable. The Tribunal carefully reviewed...MARIE GUERLAIN – DESAI V HMRC TC/2022/13097
This was an appeal about whether the purchase of a substantial dwelling house with 16.6 acres of garden and grounds that consisted of approximately 4 acres of private formal gardens and 12 acres of mature woodlands included land that was not garden or grounds of the dwelling so that the...SIMON AND JOANNE HOLDING V HMRC TC/2020/02201
This was a decision about whether all the land sold with a country house extending to 40.6 acres formed part of the grounds of the dwelling so that the taxpayers' purchase of the property was wholly residential instead of mixed-use. Patrick Cannon represented the taxpayers in this in-person hearing in...Contact Us
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