cannon-chambers-logo
Menu

Let's discuss how we can help you.

For tax advice and representation with some of the UK’s leading specialist tax advisers please contact Cannon Chambers

Get in touch

MUDAN V HMRC TC/2022/02868

This decision of the First Tier Tax Tribunal concerned whether a house that was unsafe to occupy at the effective date of the transaction was nevertheless “suitable for use as a single dwelling” and is notable for distinguishing and not following the approach in Bewley.

Procedurally, the case was also notable amongst First Tier Tribunal tax decisions for HMRC’s extraordinary but unsuccessful attempt to ambush the taxpayer at the start of the hearing by applying to exclude the taxpayers’ various survey reports on the state and condition of the dwelling.

HMRC had not only been provided with these reports before the issue of their closure notice of June 2021 but had discussed and relied on them in the closure notice. Despite this, HMRC wanted the reports excluded on the morning of the hearing on the basis that these were “an attempt to introduce expert evidence by the backdoor”.

You can read the full decision here

You might also be interested in...

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...
Contact Us