![UT-2023-000051 - [2024] UKUT 00114 (TCC)](https://backend.juristeca.com/files/emisores/logo_ICfrj4g.png){kind=logo}
Ground 2 – submissions
Ground 2 – submissions
HMRC’s submissions
In short, HMRC objected to the FTT’s reference to the fact that the Respondents’ well-known and reputable advisers had informed HMRC that they were satisfied the Respondents’ returns for the years in question were correct.
- Heading
- Introduction
- Legislation
- Applicable case-law
- Factual background
- Stephen Hitchins (deceased)
- The FTT’s Decision
- Ground 1
- Ground 2
- Ground 3
- Submissions and discussion
- Ground 1 - submissions
- The Respondents’ submissions
- Ground 1 -Discussion
- Ground 2 – submissions
- The Respondents’ submissions
- Ground 2 – Discussion
- Ground 3 – submissions
- The Respondents’ submissions
- Ground 3 – discussion
- Conclusions