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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 recent cases gives you a flavour of our member’s work

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…

MEHDI MOAREF AND ARMAGHAN MOZHDEH V HMRC

Patrick Cannon represented the taxpayers in this appeal where the tax tribunal decided that the refund of the 3% higher rates on the sale of a main residence following the acquisition of the replacement was not available when the taxpayers had purchased two side-by side apartments a few weeks apart…

WATERSIDE ESCAPES LTD V HMRC [2020]

This appeal, in which Patrick Cannon appeared for the taxpayer company, contains a detailed analysis of the scope of the 15% SDLT charge under Schedule 4A FA 2003 and whether there was ‘representative occupation” by a director and also of the sum of the lower proportions calculation in para 20…

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