Heading

Case Number: TC09615
By remote video hearing
Appeal reference: TC/2023/08527
INCOME TAX – appellant breeding and racing horses – closure notices issued by HMRC for seven years – issues raised in Statement of Case relating to offset of losses and use of UK GAAP - whether the Tribunal had the jurisdiction to decide those issues or whether excluded by scope of closure notices
Judgment date: 19 August 2025
Before
TRIBUNAL JUDGE ANNE REDSTON
Between
WILLIAM ANDREW TINKLER
Appellant
and
THE COMMISSIONERS FOR
HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Mr Keith Gordon of Counsel, instructed by UNW LLP
For the Respondents: Mr Edward Waldegrave of Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs
DECISION
- Heading
- Introduction
- Evidence
- The Closure Notices
- Closure Notice for 2010-11
- Closure Notice for 2011-12
- Closure Notice for 2012-13
- Closure Notice for 2013-14
- Closure Notices for 2014-15 and 2015-16
- The Statement of Case
- The Application and the Response
- The Scope of this hearing
- Preliminary issue
- The legislation
- Tower MCashback
- Fidex
- Investec
- The Section 66 Issue
- The parties’ submissions
- Discussion and conclusions
- The GAAP Issue
- Lower of cost and NRV
- Submissions and my view
- The year 2013-14
- Permission to amend grounds
- Conclusions
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