Lynnette Bober (Gateley Legal) takes a closer look at a case involving several diverse issues, not least the difficulties in overturning findings of fact by the FTT.
A Allam v HMRC [2021] UKUT 291 (TCC) is one of those fascinating cases where several diverse issues were considered. It also emphasises the difficulties in seeking to have findings of fact by the First-tier Tribunal (FTT) overturned on appeal to the Upper Tribunal (UT). The UT did not decide any of the issues differently to the FTT although its reasoning was different on the first procedural issue. The taxpayer’s appeals on the notices appeal entrepreneurs’ relief and business investment relief as well as HMRC’s appeal on the income tax ‘transactions in securities’ counteraction notice were therefore unsuccessful. Each of these aspects are considered in turn.
Procedural issue: the notices appeal
The taxpayer appealed against HMRC’s closure notices issued to him...
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Lynnette Bober (Gateley Legal) takes a closer look at a case involving several diverse issues, not least the difficulties in overturning findings of fact by the FTT.
A Allam v HMRC [2021] UKUT 291 (TCC) is one of those fascinating cases where several diverse issues were considered. It also emphasises the difficulties in seeking to have findings of fact by the First-tier Tribunal (FTT) overturned on appeal to the Upper Tribunal (UT). The UT did not decide any of the issues differently to the FTT although its reasoning was different on the first procedural issue. The taxpayer’s appeals on the notices appeal entrepreneurs’ relief and business investment relief as well as HMRC’s appeal on the income tax ‘transactions in securities’ counteraction notice were therefore unsuccessful. Each of these aspects are considered in turn.
Procedural issue: the notices appeal
The taxpayer appealed against HMRC’s closure notices issued to him...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
