Edward Newfield v The Commissioners for His Majesty’s Revenue and Customs [2024] UKUT 00385 (TCC)
Upper Tribunal tax and Chancery decision of JUDGE JONATHAN CANNAN on 27 November 2024
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The Appellant seeks permission to appeal a decision of the First-tier Tribunal (Tax Chamber) (“the FTT”) released on 26 January 2024 (“the Decision”). The FTT refused permission to appeal in a decision notice released on 28 March 2024. The Appellant renewed his application to the Upper Tribunal and permission was refused on paper on 29 August 2024. The Appellant requested an oral reconsideration of that decision and the hearing took place on 13 November 2024. Mr Newfield attended in person and Mr Max Simpson attended on behalf of HM Revenue & Customs (“HMRC”).