MICHAEL BENTLEY V HMRC [2021]

This appeal involved Follower Notices and penalties for failing to take corrective action following the receipt by the taxpayer of follower notices from HMRC. After a fairly extensive examination of the taxpayer by Patrick Cannon and cross-examination by HMRC, Patrick persuaded the tax tribunal to allow a substantial reduction in the amount of the penalties levied by HMRC.

Read the full decision here.

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L-L-O CONTRACTING LIMITED AND OTHERS V HMRC [2025] UKUT 00127 (TCC)

This was the hearing before the Upper Tribunal of the appellants' claims for overpayment relief from SDLT under paragraph 34 Schedule 10 FA 2003 in circumstances where the appellants had failed to claim Multiple Dwellings Relief ("MDR") in their return or in an amendment to their return, within 12 months...

CHARLIE JOHNSON V HMRC TC/2024/00254

This was a successful appeal by the taxpayer about whether multiple dwellings relief ("MDR") from SDLT applied to his purchase of a residential property with a self-contained annex. In a carefully structured and considered decision the FTT reviewed the evidence thoroughly and held that HMRC's objections concerning the interconnecting doors and shared...

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