InB & K Lavery Property Trading Partnership v HMRC[2016] UKUT 525 (1 December 2016) the UT dismissed the taxpayer’s appeal against the FTT’s decision not to strike out HMRC’s case.
The underlying dispute related to a claim for a loss of over £7m attributable to a ‘net realisable value adjustment’ in respect of two properties owned by the partnership. Following an enquiry HMRC had issued a closure notice amending the loss to a profit of £672 285 reflecting the disallowance of the revaluation adjustment. In order for the revaluation adjustment to be taken into account both parties accepted that the partnership must have been engaged in a trade at the relevant time and also that the properties must have been held as trading stock.
During the enquiry and up until HMRC’s skeleton argument was served shortly...
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InB & K Lavery Property Trading Partnership v HMRC[2016] UKUT 525 (1 December 2016) the UT dismissed the taxpayer’s appeal against the FTT’s decision not to strike out HMRC’s case.
The underlying dispute related to a claim for a loss of over £7m attributable to a ‘net realisable value adjustment’ in respect of two properties owned by the partnership. Following an enquiry HMRC had issued a closure notice amending the loss to a profit of £672 285 reflecting the disallowance of the revaluation adjustment. In order for the revaluation adjustment to be taken into account both parties accepted that the partnership must have been engaged in a trade at the relevant time and also that the properties must have been held as trading stock.
During the enquiry and up until HMRC’s skeleton argument was served shortly...
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