Tower MCashback 3 LLP v Revenue & Customs [2014] UKFTT 1081 (TC) (05 December 2014)
The application to reinstate the appeals was refused because TM 3 LLP's claim for capital allowances in respect of expenditure on the purchase of patent rights had no reasonable prospect of success, as there was no evidence that TM 3 LLP acquired any patent rights during the relevant period.
- Citation
- [2014] UKFTT 1081
- Parties
- Appellant: Tower MCashback 3 LLP; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 05 December 2014
- Procedural Posture
- Tax Appeal / Application to Reinstate Withdrawn Appeals
- Outcome
- Application to reinstate appeals refused
- Legal Topics
- Capital Allowances, Withdrawal and Reinstatement of Appeals, Standing of Members in LLP, Patent Allowances, Alternative Dispute Resolution
Case Brief
Summary, issues, holding and outcome
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Parties
Tower MCashback 3 LLP
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Tax Appeal / Application to Reinstate Withdrawn Appeals
Legal Issues
- 1 Whether the appeals withdrawn by TM 3 LLP should be reinstated
- 2 Whether Mr Marsden had standing to withdraw the appeals
- 3 Whether Mr Smith had standing to apply for reinstatement
Ratio Decidendi
The application to reinstate the appeals was refused because TM 3 LLP's claim for capital allowances in respect of expenditure on the purchase of patent rights had no reasonable prospect of success, as there was no evidence that TM 3 LLP acquired any patent rights during the relevant period.
Court Disposition
Application to reinstate appeals refused
Full Case Text
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