Upper Tribunal Tax and Chancery Chamber UT/2022/000131 - [2025] UKUT 00063 (TCC) Fecha: 04-Nov-2024 Conclusions Conclusion and Disposition58.In conclusion, we are satisfied that although the FTT’s decision could have been better expressed, it made no error of law in reaching its decision.59.The appeal is therefore dismissed.JUDGE NICHOLAS ALEKSANDERJUDGE KEVIN POOLERelease date: 19 February 2025 Heading Introduction The Background Judge Jones also granted permission to appeal on the following additional new grounds Absence of cross-examination of Mr Rafferty Ground 1 - One or two households Ground 2 – Discovery assessments Ground 3 – penalties for deliberate conduct Conclusions