The strike out application
The strike out application
The strike out application is made under Rule 8(2)(a) of the Rules on the basis that the tribunal does not have jurisdiction in relation to the proceedings. The grounds for this application are that the appellant’s skeleton argument (which was submitted in relation to the f and bp application and the disclosure application) show that the only basis for the appeal against the closure notices concerns the calculation of the appellant’s liability under the self-assessment statements, something which is not justiciable before the tribunal.
- Heading
- INTRODUCTION
- THE LAW
- THE EVIDENCE AND THE FACTS
- THE APPLICATIONS
- The Disclosure application
- The strike out application
- DISCUSSION
- Neither the grounds of appeal nor anything subsequently set out in the appellant’s skeleton argument provide sufficient information of the basis of challenge to enable HMRC to draft its statement of c
- My view
- Conclusions
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