The partners made substantial claims to tax relief under ICTA 1988 s 353.
In October 2007 HMRC began an enquiry into the partnership’s tax return for 2006/07.
In May 2009 HMRC issued a closure notice determining that the partnership had not been carrying on a trade so that the partners were not entitled to the tax relief which they had claimed.
The partnership appealed and in September 2010 the First-tier Tribunal directed that the case should be listed for a pre-trial review (see Decision TC00713).
HMRC subsequently submitted a witness statement by a chartered accountant.
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