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The Respondents’ submissions
The Respondents’ submissions
Mr Gordon submitted that HMRC had had every opportunity to request that Mr Cassidy be recalled as a witness to clarify his firm’s understanding of the statutory provisions, in case it differed from that of HMRC. They did not choose to take this course of action and it was inappropriate to use an appeal as a second opportunity to doubt Crowe LLP’s technical prowess.
- 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