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V Patel and others v HMRC

In V Patel and others v HMRC [2019] UKFTT 620 (10 October 2019) the FTT found that shares had been overvalued for the purpose of obtaining relief under ICTA 1988 s 587B.

HMRC had applied to strike out the appeals and then served a notice of objection to the withdrawal of the appeals under TMA 1970 s 54(4)(b) on the grounds that as the expert evidence made plain ‘the amount of tax owing in the closure notices as issued was understated’. HMRC therefore wished the appeal to proceed to a hearing so that the tribunal could determine in accordance with s 50 the proper amount of tax to be assessed. Two of the appellants however opposed the re-instatement and the FTT found that HMRC’s application that their appeals be reinstated could not succeed. Their appeals remained struck out with the effect that their liability to tax...

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