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.
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...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 in first tier tax tribunal listings on the approach of the tax tribunal to apportioning the purchase price to different buildings on a “just and reasonable” the basis for SDLT purposes. Patrick Cannon represented the taxpayer company and defeated HMRC’s attempt to apportion the...Contact Us
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