Supreme Court petitioned to hear Hoey appeal

In my article titled ‘Friday the 13th’ (Taxation 2 June 2022 page 8) I looked at the recent Court of Appeal decision in Hoey and others v CRC [2022] EWCA Civ 656 and raised a number of issues that I felt should be of concern to the wider profession. Little since has dissuaded me from those views.

Are the scales of justice evenly balanced?

Taxpayers are rightly expected to make full disclosure of their affairs to HMRC and are criticised by HMRC and the courts if there is a lack of candour during enquiries or during legal proceedings. Witnesses are dismissed as unreliable if a court feels it is getting at best only half a story. But is the bar set at the same level for HMRC?

Pulling teeth

Among the concerns my previous article raised was the piecemeal way in which...