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I really enjoyed reading the decision in the Harrison case (see page 6 for our summary). Partly this was for the Monty Python reference. As a teenager I always looked forward to new episodes of the show and now find it a sobering thought that the dead parrot first joined the choir invisible over 50 years ago.
But also I found it fascinating for the inventive – perhaps audacious would be a better word – attempt to reinvigorate the staleness argument that we had all assumed had been consigned to tax history by the Supreme Court decision in Tooth. Although the argument was ultimately dismissed, the fact that: (a) permission had been granted to appeal on the point; and (b) the Upper Tribunal took 36 paragraphs to reach a conclusion on the question, shows that it was not a forgone conclusion that the appeal would fail.
Arguments on such fine points are to me one of the fascinations of being a tax adviser, but at the same time I can understand why clients get so frustrated that we can’t always give them a clear black and white answer. Anybody who regularly looks at our Readers’ forum knows that we live in a world where almost nothing is certain.
Monty Python was not kind to accountants: ‘Your report here says that you are an extremely dull person. You see, our experts describe you as an appallingly dull fellow, unimaginative, timid, lacking in initiative, spineless, easily dominated, no sense of humour, tedious company and irrepressibly drab and awful. And whereas in most professions these would be considerable drawbacks, in chartered accountancy they are a positive boon.’
Surely nobody could ever say the same thing about tax advisers!
If you do one thing...
Look at paragraph 81 of the Court of Appeal’s decision in T Good v CRC – very uncomfortable reading (tinyurl.com/ewcagood).
