The First-tier Tribunal refused HMRC permission to appeal against decisions of the tribunal including that HMRC must particularise its case and the reasons for issuing income tax determinations to the appellant amounting to £96,037,893.  

On 11 July 2016, HM Revenue and Customs (HMRC) commenced a long-running compliance check of the appellant, in connection with the provisions relating to salaried members of limited liability partnerships. During that compliance check, HMRC asked 81 individual questions concerning the application of the salaried members rules and was sent over 1,000 pages of detailed and relevant evidence. On 8 March 2024, HMRC issued the appellant with determinations (under SI 2003/2682, reg 80) totalling £96,037,893 for 2017/18 to 2019/20. HMRC did not state any reasons in the determinations or the covering correspondence. The appellant appealed the determinations to the First-tier Tribunal (FTT), and HMRC applied for the