Langsam v Revenue and Customs (Procedure - Rule 23 Tribunal Procedure (First-tier Tribunal) (Tax Chamber Rules) 2009 'Allocation of cases to categories' - Appeal initially allocated as a Basic case - Application by Appellant for appeal to be re-categorised to Standard case) [2025] UKFTT 404 (TC) (04 April 2025)

Langsam v Revenue and Customs (Procedure - Rule 23 Tribunal Procedure (First-tier Tribunal) (Tax Chamber Rules) 2009 'Allocation of cases to categories' - Appeal initially allocated as a Basic case - Application by Appellant for appeal to be re-categorised to Standard case) [2025] UKFTT 404 (TC) (04 April 2025)

The appeal is an information notice appeal, which is appropriately categorised as a Basic case under Rule 23 and the Practice Direction. There is no material dispute of fact, the issues are legal, and a video hearing is suitable. No justification exists for re-allocation to Standard category.

Citation
[2025] UKFTT 404
Parties
Appellant: Alexander Langsam; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
04 April 2025
Procedural Posture
Tax Appeal (first Tier Tribunal) / Application for Re Allocation of Case Category (basic to Standard) Determined on the Papers
Outcome
Application for re-allocation dismissed; appeal to proceed as Basic case.
Legal Topics
Case Categorisation, Information Notice Appeals, Tribunal Procedure, Judicial Review Overlap
Tax Law Administrative Law Case Categorisation Information Notice Appeals Tribunal Procedure Judicial Review Overlap

Case Brief

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Parties

Alexander Langsam

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (first Tier Tribunal) / Application for Re Allocation of Case Category (basic to Standard) Determined on the Papers

Legal Issues

  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 is an information notice appeal, which is appropriately categorised as a Basic case under Rule 23 and the Practice Direction. There is no material dispute of fact, the issues are legal, and a video hearing is suitable. No justification exists for re-allocation to Standard category.

Court Disposition

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

Orders

  • Appeal to proceed as originally categorised (Basic case) and determined by video hearing.
  • Directions for skeleton arguments and authorities bundle issued separately.