TC09574 - [2025] UKFTT 00852 (TC)

Case Number: TC09574

In public by remote video hearing

Appeal reference: TC/2023/10945

INCOME TAX – film schemes – partnership closure notices – consequential amendments – not appealable but could they be within s31(d) or s 32 TMA? - no on the facts - application to strike out appeals by appellant for lack of jurisdiction – application granted

Heard on: 16 April 2025 with written submissions received in June 2025

Judgment date: 10 July 2025

Before

TRIBUNAL JUDGE NIGEL POPPLEWELL

Between

MICHAEL KELLY

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: In person

For the Respondents: Omar Riaz litigator of HM Revenue and Customs’ Solicitor’s Office

DECISION