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Correct location of judicial review claim

25 January 2024
Issue: 4922 / Categories: Tax cases
The King (on the application of A Bale) v CRC, King's Bench Division, 15 December 2023)

The taxpayer lived in the Wirral and was a director of a company based in Liverpool. HMRC served him a personal liability notice for alleged personal responsibility for inaccurate PAYE returns submitted by the company. The notice covered a penalty in the sum of £124.9m.

The taxpayer issued judicial review proceedings. He appointed a solicitor based in Liverpool who instructed counsel based in London. In the judicial review claim form the taxpayer’s representatives stated that the south-east region was the area with which the claim was most closely connected. As a result the hearing was allocated to the administrative court in London. The court service attempted to move the hearing to the court in Manchester as the nearest centre to Liverpool. The taxpayer objected saying there was no particular public interest that the proceedings be heard in Manchester. Further it would be more expensive because of the...

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