Alexander Langsam v The Commissioners for HMRC

Alexander Langsam v The Commissioners for HMRC

The appeal concerns an information notice and, absent material factual dispute or need for complex case management, should remain a Basic case. The issues are legal, not factual, and a video hearing is suitable. There is no practical advantage to re-allocation, and the Practice Direction supports the current categorisation.

Parties
Appellant: Alexander Langsam; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
04 August 2025
Procedural Posture
Tax Appeal (allocation of Case Category) / Interlocutory Application for Re Allocation From Basic to Standard Case
Outcome
Application for re-allocation dismissed; appeal to proceed as Basic case.
Legal Topics
Case Categorisation, Information Notice Appeals, Judicial Review Overlap, Video Vs Hybrid Hearings

Case Brief

Summary, issues, holding and outcome

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Parties

Alexander Langsam

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (allocation of Case Category) / Interlocutory Application for Re Allocation From Basic to Standard Case

  1. 1 Whether the appeal should be re-allocated from Basic to Standard case category under Rule 23
  2. 2 Whether the complexity of legal issues or need for witness evidence justifies re-allocation

Ratio Decidendi

The appeal concerns an information notice and, absent material factual dispute or need for complex case management, should remain a Basic case. The issues are legal, not factual, and a video hearing is suitable. There is no practical advantage to re-allocation, and the Practice Direction supports the current categorisation.

Court Disposition

Application for re-allocation dismissed; appeal to proceed as Basic case.

Orders

  • Appeal to remain categorised as Basic case.
  • Appeal to be determined by video hearing.