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) / Interlocutory (applications to Strike Out, Amend Grounds, and for Disclosure)

Legal Issues

1. 1 Whether the tribunal has jurisdiction over the appeal against closure notices and associated tax calculations
2. 2 Whether the appellant's grounds of appeal are sufficiently particularised
3. 3 Whether HMRC must provide further disclosure

Ratio Decidendi

The tribunal has jurisdiction because the appeal is against amendments made by closure notices and tax calculations, not merely the self-assessment statements. The appellant must amend his grounds of appeal to provide sufficient legal and factual detail. HMRC is not required to provide further disclosure at this stage. The strike out and disclosure applications are dismissed; the application for further and better particulars is granted.

Court Disposition

HMRC's strike out and disclosure applications dismissed; HMRC's application for further and better particulars granted.

Orders

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