In GM Wildin v HMRC (TC01782 – 15 February) an accountant began in business in 1981 and transferred his business to an associated company in 2003. HMRC issued an amendment to his self-assessment increasing the CGT liability on the disposal and he appealed contending that the amendment understated the valuation of the goodwill of his business at March 1982. He subsequently applied to amend the grounds of appeal to include a contention that the valuation of the business at the date of disposal was excessive. HMRC opposed the application but the First-Tier Tribunal granted it. Judge Mosedale held that ‘neither the delay nor extra costs are grounds on which leave to amend the grounds of appeal should be refused’.
Why it matters: TMA 1970 s 31A(5) requires an appellant to specify his grounds of appeal. The accountant...
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In GM Wildin v HMRC (TC01782 – 15 February) an accountant began in business in 1981 and transferred his business to an associated company in 2003. HMRC issued an amendment to his self-assessment increasing the CGT liability on the disposal and he appealed contending that the amendment understated the valuation of the goodwill of his business at March 1982. He subsequently applied to amend the grounds of appeal to include a contention that the valuation of the business at the date of disposal was excessive. HMRC opposed the application but the First-Tier Tribunal granted it. Judge Mosedale held that ‘neither the delay nor extra costs are grounds on which leave to amend the grounds of appeal should be refused’.
Why it matters: TMA 1970 s 31A(5) requires an appellant to specify his grounds of appeal. The accountant...
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