The First-Tier Tribunal was asked to examine whether a significant change in business was in fact a cessation of one trade and the establishment of another. If so, the taxpayer would be able to claim …

The question of what constitutes a ‘discovery’ continues to cause disagreements between HMRC and taxpayers.  A further case on the matter was recently heard by the Upper Tier Tribunal.  Interestingly, the question of negligence on …

The case of A Dickinson involved private residence relief and rested on when the character of land ceases to be that of garden and grounds where there is development planned. Background The taxpayer owned a …

The case law surrounding the grounds on which HMRC can raise Discovery assessments continues to develop, and a further case on the matter was recently heard in favour of the taxpayer.  In another recent case …

Background In this recent case, the taxpayer Paul Gibson purchased a property called Moles House for £715,000. Mr Gibson decided to demolish the original house (referred to by HMRC as Moles House One) so as …