TC09615 - [2025] UKFTT 01016 (TC)
First-tier Tribunal (Tax Chamber)

TC09615 - [2025] UKFTT 01016 (TC)

Fecha: 31-Jul-2025

Heading

Neutral Citation: [2025] UKFTT 01016 (TC)

Case Number: TC09615

FIRST-TIER TRIBUNAL
TAX CHAMBER

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

Heard on: 31 July 2025

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