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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.

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...

JAMES FAIERS V HMRC TC/2021/02112

This decision of the FTT turned on whether the presence of a pole and electricity cables overflying a garden meant that the part of the garden affected was not a residential property for SDLT purposes. The taxpayer was represented by Patrick Cannon, and the decision contains a useful survey of...

DANIELLE AND EMMA SEXTON V HMRC TC/2022/00160

Patrick Cannon represented the taxpayers in this appeal relating to the purchase of a long lease of a flat which came with an easement allowing the use of a communal garden in a square adjacent to the building housing the flat. The tribunal held that this was not a purchase of mixed-use land...

Ladson Preston Ltd and AKA Developments Greenview Ltd v HMRC [2022] UKUT 0031 (TCC)

This is an appeal to the Upper Tribunal about Multiple Dwellings Relief for SDLT purposes ("MDR"), in which Patrick Cannon represented the taxpayers. The UT was asked to decide (1) when buildings were in the process of being constructed for use as dwellings for MDR purposes and (2) whether activities...

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...
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