In W Tinkler v HMRC [2025] UKFTT 1016 (TC) (19 August) the FTT considered the taxpayer’s application for it to decide that HMRC were prevented by the scope of its closure notices from raising two alternative arguments in the appeal ruling in favour of HMRC in relation to both arguments.
The taxpayer submitted returns for seven years on the basis that he had carried on a single trade consisting of breeding horses and training/racing horses. HMRC opened enquiries and issued closure notices which stated for six of the seven years that the trade losses had been overstated. They added that in HMRC’s view the taxpayer carried on a trade as a breeder but that the horse racing activity was not a trade. The result was a substantial reduction in the amount of the losses. In the seventh year the taxpayer...
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In W Tinkler v HMRC [2025] UKFTT 1016 (TC) (19 August) the FTT considered the taxpayer’s application for it to decide that HMRC were prevented by the scope of its closure notices from raising two alternative arguments in the appeal ruling in favour of HMRC in relation to both arguments.
The taxpayer submitted returns for seven years on the basis that he had carried on a single trade consisting of breeding horses and training/racing horses. HMRC opened enquiries and issued closure notices which stated for six of the seven years that the trade losses had been overstated. They added that in HMRC’s view the taxpayer carried on a trade as a breeder but that the horse racing activity was not a trade. The result was a substantial reduction in the amount of the losses. In the seventh year the taxpayer...
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