Brown v Revenue & Customs [2014] UKFTT 984 (TC) (24 October 2014)
HMRC did not act unreasonably in defending or conducting the proceedings. The fact that HMRC's case was ultimately unsuccessful does not entitle the Appellant to costs. There was no evidence of unreasonable conduct by HMRC under Rule 10(1)(b).
- Citation
- [2014] UKFTT 984
- Parties
- Appellant: Gordon Brown; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 24 October 2014
- Procedural Posture
- Costs Application Following Substantive Tax Penalty Appeal / Post Substantive Appeal, Costs Application Decision
- Outcome
- Application for costs refused
- Legal Topics
- Costs in Tribunal, Reasonable Excuse for Late Payment, Time to Pay Arrangements, Tribunal Procedure Rules
Case Brief
Summary, issues, holding and outcome
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Parties
Gordon Brown
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Costs Application Following Substantive Tax Penalty Appeal / Post Substantive Appeal, Costs Application Decision
Legal Issues
- 1 Whether HMRC acted unreasonably in defending or conducting proceedings under Rule 10(1)(b) of the Tribunal Procedure Rules 2009
- 2 Whether Appellant is entitled to costs order against HMRC
Ratio Decidendi
HMRC did not act unreasonably in defending or conducting the proceedings. The fact that HMRC's case was ultimately unsuccessful does not entitle the Appellant to costs. There was no evidence of unreasonable conduct by HMRC under Rule 10(1)(b).
Court Disposition
Application for costs refused
Orders
- No order as to costs
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