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.
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...GUERLAIN-DESAI V HMRC TC/2022/13097
This was a successful application by Patrick Cannon to the FTT for the taxpayer to bring her appeal 42 days after the 30-day period for giving notice of appeal against a closure notice had expired. This was a mixed-use SDLT appeal, and HMRC had amended the taxpayer’s return to show...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...Contact Us
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