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APPEALS


Application to amend grounds of appeal refused.
Card image Lauren Redhead Emily Burke Clara Boyd
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).
HMRC appears to view many penalty appeals as a ‘second bite of the cherry’, even where the tribunal has not considered the earlier decision, writes Anastasia Nourescu (Stewarts). 
The Upper Tribunal decisions in Altrad Services, BlackRock and Euromoney are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.
A report by Tolley®Guidance on making appeals and applications to the First-tier Tribunal during the Covid-19 pandemic, with insight on appealing to the Upper Tribunal and judicial review.
A 20 questions guide, by Adam Craggs and Constantine Christofi (RPC).
Andrew Goldstone (Mishcon de Reya) believes that a recent case raises concerns over HMRC’s approach to litigation and illustrates the need for change in the EIS legislation. 
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