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F Warren (TC5970)
Costs when appellant substituted for previous party
The taxpayer was a member of a limited liability partnership (LLP) and had been substituted as the appellant in place of the LLP in its appeal against HMRC.
The Revenue later issued a partnership follower notice (FA 2014 s 204) to the LLP and a copy was sent to the taxpayer. The corrective action required by the notice included the withdrawal of the appeal. This presented the taxpayer with a dilemma: if he did not withdraw the appeal he might face penalties. In the event he withdrew his appeal and HMRC applied for costs.
The case had been categorised as complex. The taxpayer said he had not had the opportunity to opt out of the cost-sharing regime because he had not been the appellant when the case was categorised.
However the First-tier Tribunal said that when the tribunal substitutes an...
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