In Swallow v HMRC (TC00742 – 20 October) an individual (S) claimed loss relief of more than £300 000 relating to alleged trading in biofuels and paper pulp. HMRC formed the opinion that the claimed loss was part of a tax avoidance scheme and that the promoters of the scheme may have committed a criminal offence. It began an enquiry into the scheme and subsequently issued a closure notice amending S’s self-assessment and rejecting his claim for loss relief. S appealed to the First-Tier Tribunal.
HMRC applied for the appeal proceedings to be stayed for six months and for an extension of time to serve their Statement of Case giving evidence that about 360 traders and 19 limited liability partnerships had made similar claims and that tax of more than £40 000 000 was at stake. S opposed the application but the Tribunal...
