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 against an information notice and its allocation as a Basic case is consistent with Rule 23 and the Practice Direction. There is no material dispute of fact, only legal issues, and a short video hearing is suitable. No justification exists for re-allocation to Standard case.

Citation
[2025] UKFTT 404 (TC)
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 From Basic to Standard Case; Determined on Papers
Outcome
Application dismissed
Legal Topics
Case Categorisation, Information Notice Appeal, Practice Direction Application, Jurisdiction of Tribunal
Tax Law Tribunal Procedure Case Categorisation Information Notice Appeal Practice Direction Application Jurisdiction of Tribunal

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 From Basic to Standard Case; Determined on Papers

Legal Issues

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

Ratio Decidendi

The appeal is against an information notice and its allocation as a Basic case is consistent with Rule 23 and the Practice Direction. There is no material dispute of fact, only legal issues, and a short video hearing is suitable. No justification exists for re-allocation to Standard case.

Court Disposition

Application dismissed

Orders

  • Appeal to proceed as Basic case by video hearing
  • Directions for skeleton arguments and authorities bundle issued separately