TC09588 - [2025] UKFTT 00876 (TC)

This case management decision deals with three applications (“the applications”) which arise from appeals brought by the appellant in respect of final closure notices (“the closure notices”) issued by HMRC for the tax years 2007/2008, 2008/2009, and 2009/2010 (“the years in question”).

In chronological order, the applications are:

HMRC’s application dated 26 July 2024 (entitled an application for further and better particulars) that the appellant files amended and detailed grounds of appeal (“the f and bp application”).

The appellant’s application dated 19 August 2024 for an order that HMRC makes specific disclosure of certain documents and information (“the disclosure application”).

HMRC’s application dated 25 June 2025 that the appellant’s appeals be struck out (“the strike out application”).

For the reasons given later in this decision, I have dismissed the strike out application and the disclosure application and I have granted the f and bp application.

I am grateful to Ms Brown and to Mr McKee for their oral and written submissions at and prior to the hearing. I have considered these in detail even though I have not found it necessary to refer to each and every one of them in reaching my conclusions.