An application by HMRC to strike out appeal proceedings by the appellants was upheld, on the basis that those appeals were settled by agreement under TMA 1970, s 54.
HM Revenue and Customs (HMRC) applied to the First-tier Tribunal (FTT) for appeals made by the appellants to be struck out, on the grounds that those appeals had been settled by agreement under TMA 1970, s 54.
The appellants were employed by the same company. They were members of the company’s share scheme. Following enquiries into the appellants’ tax returns for 2006/07, HMRC issued closure notices on the basis that capital gains declared in respect of the disposal of scheme shares were assessable to income tax. HMRC subsequently advised that a ‘test case’ concerning the share scheme had been subject to a review, resulting in revised computations for each appellant.
Following discussions and correspondence, one of the
