Summary
A claim for judicial review of decisions by HM Revenue and Customs (HMRC) to deny loss relief claims in respect of the claimants’ investments in film partnerships was dismissed by the Upper Tribunal (UT), which found that HMRC had acted correctly and according to the law.
Background
The claimants were members of a number of film partnerships. The relevant film partnerships claimed to have suffered substantial trading losses for 1999/00 to 2001/02 inclusive. HMRC opened enquiries into the partnership returns, and subsequently issued closure notices disallowing those losses. The partnerships appealed. Following a settlement agreement, the partnership losses were considerably reduced.
One claimant (DS) included a claim in his 1998/99 tax return to offset film partnership losses in other years (including 1999/00) so as to reduce his tax payment for
