Priestley v Revenue and Customs (INCOME TAX - case management - appeal against a final closure notice - HMRC application to strike out - HMRC application for a direction that the appellant amends his grounds of appeal - appellant's application for specific disclosure) [2025] UKFTT 876 (TC) (18 July 2025)

Parties

Procedural Posture

Income Tax Appeal / Case Management Decision on Interlocutory Applications

Legal Issues

1. 1 Whether the tribunal has jurisdiction over the appellant's appeal against closure notices and associated tax calculations
2. 2 Whether the appellant must amend and particularise his grounds of appeal
3. 3 Whether HMRC must provide specific disclosure of documents and information relating to tax liability calculations

Ratio Decidendi

The tribunal has jurisdiction because the appellant's challenge is to the amendments made by the closure notices and tax calculations, not merely the self-assessment account balance. However, the appellant must amend his grounds of appeal to set out the legal and factual basis of his challenge in sufficient detail. The disclosure application is rejected as the onus is on the appellant to particularise his case, and the tribunal has no jurisdiction over the self-assessment statements.

Court Disposition

HMRC's strike out application dismissed; HMRC's application for amended grounds of appeal granted; appellant's disclosure application dismissed.

Orders

• Appellant to file and serve amended grounds of appeal within 60 days detailing legal and factual grounds relied upon.
• HMRC's requirement to provide a statement of case is stayed until 60 days after appellant's compliance.