This decision in my own penalty appeal emphasises the importance of HMRC keeping an open mind and not pursuing to a full appeal hearing a “myopic” belief that the taxpayerfft has behaved dishonestly. This belief, said the judge, fed into the evidentially unsupported and opportunistic allegation of perjury that was put to me in cross-examination during the hearing.
Read the costs decision of Judge Geraint Jones QC here. The decision of Judge Jones QC in the substantive appeal is available here.
