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
Legal Issues
- 1 Whether the appeal should be re-allocated from Basic to Standard case category under Rule 23
- 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.
Full Case Text
Judgment text and source record
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