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A practical insight into the appeal process when taking a case to the First-tier Tribunal.
KEY POINTS
- Reflect at every stage of the process to ascertain whether it is commercially viable to carry on fighting.
- Familiarity with each step of the appeal process.
- Record key dates on a calendar.
- In advance of the First-tier Tribunal hearing prepare speaking notes and memorise opening address.
In a dispute with HMRC it is always preferable if the adviser can reach a negotiated settlement with the department because this enables the substantive issue to be resolved a lot quicker and at reduced professional costs. Most enquiry cases opened by HMRC that give rise to an underpayment of taxes are resolved in a pragmatic way with agreement reached between HMRC and the client.
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