David (instructed by Vince Curley) appeared for the successful taxpayer in this appeal in which the Tribunal quashed £9million of assessments which had been issued by HMRC on the Kittel/Mecsek basis.
Following extensive cross examination of the decision making officer and detailed legal submissions in relation to the cogency of the evidence adduced by HMRC, the Tribunal accepted that the Appellant did not have knowledge or means of knowledge of fraud. Accordingly, the assessments were discharged in full.
The full decision can be seen here.
This is the third decision in the past 12 months in which David has acted for taxpayers who have successfully overturned Kittel assessments.