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.
James and Charlotte Averdieck V HMRC TC/2022/02324
This is the first appeal about mixed-use residential and non-residential property for SDLT in the wake of the Court of Appeal’s decision on the meaning of “grounds of a dwelling” in Hyman and Goodfellow v HMRC [2022] EWCA Civ 185. Patrick Cannon represented the taxpayers who sought to establish that…SC Properties Ltd and Richard Cooke v HMRC [2022] UKFTT 214 (TC)
Our member, Patrick Cannon represented the taxpayers in this appeal which concerned whether a husband and wife property development partnership existed and illustrates the challenges involved in persuading the FTT of the existence of a valid partnership between spouses as distinct from simple joint ownership of a development property. You…Marcus And Marcus Limited V HMRC [2022] UKFTT 145 (TC)
This is now the leading case on the approach of the tax tribunal to apportioning the purchase price to different buildings on a “just and reasonable” basis for SDLT purposes. Patrick Cannon represented the taxpayer company and defeated HMRC’s attempt to apportion the price paid for a property consisting of…Hyman and Goodfellow v HMRC [2022] EWCA Civ 185
This is the judgment of the Court of Appeal in which Patrick Cannon represented the appellants who sought to establish a workmanlike and coherent meaning of the phrase “grounds of a building” within the definition of “residential property” for SDLT purposes in section 116(1)(b) FA 2003. The Court of Appeal…THE WAKELYN TRUST V HMRC [2022] TC/2019/01108/V
This was an appeal to the FTT over whether the release of a tenant’s reinstatement obligation contained in a lease formed deductible expenditure of the lessor for the purpose of section 38(1)(b) Taxation of Chargeable Gains Act 1992. Patrick Cannon represented the taxpayer trust in this appeal and the decision…Contact Us
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