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.
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...Victoria Carter & Peter Kennedy v HMRC [2021] UKUT 300 (TCC)
This was an appeal to the Upper Tribunal in which Patrick Cannon appeared for the taxpayers. The appeal concerned whether a hypothetical officer of HMRC could reasonably have been expected to have been aware that the self-assessment to tax was insufficient based on the information made available when the enquiry...ROBERT DAVID GEORGE RACHEL CLAIRE GEORGE VS THE COMMISSIONERS FOR HMRC
This was a decision of Judge Poon on an appeal for a claim for multiple dwellings relief that was heard before the Upper Tribunal's decision in Fiander and Brower but delayed by the judge to take account of the Upper Tribunal's decision. The decision has some detailed remarks on the...SMITH HOMES 9 LTD V REVENUE AND CUSTOMS COMMISSIONERS [2021]
This was an unsuccessful application by HMRC to strike out the taxpayer’s appeal against a closure notice refusing overpayment relief for multiple dwellings relief on a claim by the taxpayer which was made more than 12 months after the filing date of the SDLT return under para 34 Sch 10...LADSON PRESTON LTD AND AKA DEVELOPMENTS GREENVIEW LTD V HMRC [2021]
These two appeals related to claims for multiple dwellings relief from SDLT where the dwellings had not yet been built at the effective date of the transaction and the relevance of the prior grant of planning permission for the construction of the dwellings and also where construction work had begun...Contact Us
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