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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.

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...

NELLSAR LTD v HMRC [2023] UKFTT 718 (TC)

This was an in-person appeal heard over six days about a corporation tax deduction for goodwill acquired on the purchase of care home businesses, including their properties. It was decided that open market fair values (and not the depreciated replacement cost used by the taxpayer) of the land and buildings...

KOZLOWSKI v HMRC TC/2023/00327

This was an SDLT mixed-use claim from a respected FTT judge who importantly decided that (1) a property must fall within section 116(1) as residential before Schedule 4ZA can apply to it; (2) genuine commercial use of land that would otherwise be garden or grounds of a dwelling takes it...

BLOOM V HMRC TC/2020/01423

This was an SDLT mixed-use overpayment relief claim for £265,750 which turned on whether the presence of a sewage treatment plant (“STP”) located on the taxpayers’ property and which served the dwelling and the neighbouring flats, formed part of the garden or grounds of their dwelling. The FTT weighed up...

SUTERWALLA v HMRC TC/2022/03979

This decision is a significant taxpayer win over whether a paddock was part of the grounds of a dwelling house for SDLT mixed-use purposes. The FTT accepted Patrick Cannon’s submissions that, on the evidence, a paddock abutting the garden of a dwelling house did not perform any function in relation...

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