PAUL BAXENDALE-WALKER v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00154 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Mark Baldwin on 28 July 2023
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Rule 8(3)(c), Tribunal Procedure (Upper Tribunal) Rules 2008 - application to strike out an application by HMRC for a tax-related penalty under paragraph 50, Schedule 36, Finance Act 2008 – whether statutory conditions in paragraph 50 clearly not met – yes - whether HMRC’s application having no reasonable prospect of success – yes – application allowed.