Tower MCashback 3 LLP v Revenue & Customs [2014] UKFTT 1081 (TC) (05 December 2014)
The application to reinstate the appeals was refused because, even though the applicant had standing and acted in good faith, there was no evidence that TM 3 LLP acquired any patent rights or incurred qualifying expenditure, and thus the appeals had no reasonable prospect of success.
- Citation
- [2014] UKFTT 1081 (TC)
- 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- Tax Appeal / Application to Reinstate Withdrawn Appeals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, Patent Allowances, Withdrawal and Reinstatement of Appeals, Standing of Board Members, 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Tax Appeal / Application to Reinstate Withdrawn Appeals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- 1 Whether the application to reinstate withdrawn appeals should be granted
- 2 Whether the applicant had standing to apply for reinstatement
- 3 Whether the appeals have a reasonable prospect of success
Ratio Decidendi
The application to reinstate the appeals was refused because, even though the applicant had standing and acted in good faith, there was no evidence that TM 3 LLP acquired any patent rights or incurred qualifying expenditure, and thus the appeals had no reasonable prospect of success.
Court Disposition
Application to reinstate appeals refused
Full Case Text
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