Notable Cases

In this appeal I represented the taxpayers in a claim for Multiple Dwellings Relief in the context of a main house plus granny annex which were connected by a short corridor but not a lockable internal door at the effective date and whether they were each suitable for use as a single dwelling. This case contains some useful analysis of the meaning of “dwelling” and the equivalent case-law for the...

In this case, the First-tier tax Tribunal considered whether enquiry notices which HMRC said were properly issued to both appellants were served on the two companies within the statutory enquiry period in accordance with Schedule 10, paragraph 12 Finance Act 2003.

I appeared for the taxpayers and successfully argued that the enquiry notices served on both taxpayers were not properly served within the relevant time limit so that the additional...

I appeared for the taxpayer in this appeal involving a claim for different rates of SDLT for residential and non-residential property arising from the presence of a grassy field adjoining a countryside house and garden and whether it was part of the grounds of the house.

Patrick Cannon appeared for the taxpayer in this SDLT appeal where the First-tier Tax Tribunal held that it was not necessary for the vendor to have knowledge of the other transactions for the provisions of Section 75A of the Finance Act of 2003 to be engaged.

Geering and others v HMRC [2018]

This case was a tax judicial review in which I appeared jointly for the taxpayers.

The divisional court held there had been a material misrepresentation of the facts by HMRC when applying for search warrants against the taxpayers and a failure to draw relevant matters to the judge’s attention.

If a fair picture had been given to the judge, he might have refused to issue the search warrants.

The search...