Jurisdiction issues

The First-tier Tribunal called a hearing to consider its jurisdiction in respect of aspects of issues raised by the appellant company which in 2004 reached a contract settlement with HMRC under which it paid tax of £525 000.

The liabilities covered became a matter of dispute. The firm’s 2002 and 2003 returns included claims for amortisation of goodwill and showed the remaining tax liability as paid. The 2004 and 2005 returns included a claim for terminal loss relief arising from the amortisation of goodwill.

The Revenue opened enquiries into all four years and issued closure notices for 2002 and 2003 refusing the amortisation claims and contesting the claim the tax due had been paid. The department issued closure notices for the remaining years denying the terminal loss relief claims.

The taxpayer lodged an appeal with the First-tier Tribunal in respect of the amendments made in the 2002...