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03 November 2009 / Mike Truman
Issue: 4230 / Categories: Comment & Analysis , Residence & domicile
Grace has been sent back to the First-tier Tribunal for reconsideration. MIKE TRUMAN looks at the judgment


  • Grace remitted to the First-tier Tribunal.
  • The Special Commissioner did not misdirect herself on ‘two residences’.
  • She did however misdirect herself on the importance of presence for employment.
  • The question of costs.

There are certain taxpayers to whom the taxpaying public as a whole and tax advisers in particular should be particularly grateful.

These are the ones who take a case through the courts long after others would have given in faced with the unplumbable depths of HMRC’s financial pockets and who therefore give us judgments on points of law that allow those who come after them to know their position with greater certainty.

Mr and Mrs Jones the shareholders in Arctic Systems Ltd were an example of this; and now we have Mr Lyle Grace. He ...

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