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• The Upper and First-Tier Tribunals – What is a Reasonable excuse?
• [02/03/2012] Detailed guidance on reasonable excuse.
• HMRC v Landsdowne Partners Ltd Partnership [2010] EWHC 2582 (Ch)
• Whether a discovery assessment was valid after HMRC discovered that they had incorrectly deducted certain expenses.
• Market Investigations Ltd v Minister of Social Security, QB[ 1968] 3 All ER 732
• Market research interviewers; employed or self-employed; worker had no conrol over work undertaken.
• Ready Mixed Concrete (South East) Ltd v Minister of Pensions and National Insurance
• Whether an owner-driver who provided his services to one company for its deliveries was employed or self-employed.
• Fall v Hitchin (1972) 49TC433
• [Whether a professional dancerl was employed or self-employed]
• First-Tier Tribunal Tax Cases – reasonable excuse
• [23/06/11] Details of four tribunal cases concerning reasonable excuse.
• Reed Employment v HMRC
• [23/06/11] The first tier tribunal case looks at the supply of temporary staff.
• Revenue & Customs Commissioners v Dr Piu Banerjee
• [23/06/11] This case looks at training costs and whether they are wholly, exclusively and necessary.
• Dr K M A Manzur v Commissioners for HMRC
• This is a first tier tribunal that looked at the whether a trade is being carried out.
• Parade Park Hotel and Another v HMRC P May v HMRC Sp C [2007] SSCD 430 (Sp C 599)
• Employment status; mutuality of obligations; whether employed or self-employed.
• G Bushell v HMRC, FTT [2010] UKFTT 577 (TC), TC00827
• [01/05/2011] Construction industry scheme, penalties for non-submission opf CIS returns.
• IR35 tax cases
• [17/12/10] Tax cases - whether IR35 applies or not.
• Income shifting cases
• [17/12/10] Important income shifting cases.
• Demibourne Ltd v HMRC Sp C [2005] SSCD 667 (Sp C 486)
• Employment status; former employee retired then re-engaged by former employer as self-employed.
• R (on the application of Davies and another) v HMRC R (on the application of Gaines-Cooper) v HMRC - [2010] All ER (D) 197 (Feb)
• [30/03/10] - Application for judicial review on ordinary residence rulings; taxpayer met the guidance in IR20 but still had strong connections with UK; interpretation of IR20
• Dr Andreas Helmut Tuczka – First Tier Tribunal Case: TC00366
• [30/03/10] - Ordinary residence; whether individual coming to UK; acquisition of home in the UK and effects on residence status.
• Walton v R & C Commrs; [2009] TC 00273
• Amendments to Self Assessment return by HMRC; whether taxpayer had discharged burden of proving incorrect assessments.
• Dragonfly Consulting Ltd v HMRC
• Whether an individual is employed or self-employed.
• EMI Group Electronics Ltd v Coldicott (aka Thorn EMI Electronics Ltd v Coldicott)
• Compensation for loss of office; contractual; whether taxable.
• Garnett v Jones (re Arctic Systems Ltd)
• Whether issue of share to wife was a settlement and, consequently, the dividends taxable on the husband.
• SCA Packaging Ltd v HMRC
• Compensation for loss of office; contractual; whether taxable and whether PAYE should have been operated.
• Hall v Lorimer (1994)
• Freelance vision mixer; whether employed or self-employed.
• Fall v Hitchen
• Professional dancer under a British Actors' Equity Association standard contract; whether employed or self-employed.
• Walker v Adams
• Compensation for loss of office including payment for 'injury to feelings'; whether taxable
• Pook v Owen
• Doctor on call from home; whether mileage allowance was taxable and whether additional motor expenses allowable.
• O'Leary v McKinlay
• UK football club; made a loan to a non-domiciled player; funds invested offshore and the player received the interest; was this an emolument from employment?
• Pepper v Hart & Others
• Income from Employment; benefits in kind; valuation of cash equivalent of benefit.

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