There was no provision in the First-tier Tribunal Rules pursuant to which HMRC could apply for the appellant’s costs application to be struck out due to insufficient detail, and the appellant was entitled to reasonable costs determined on the standard basis.  

The appellant brought to the First-tier Tribunal (FTT) an application for costs against HM Revenue and Customs (HMRC) (pursuant to TCEA 2007, s 29 and the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, rule 10 (FTT Rules)). The appeal to which the claim related concerned a tax charge levied by way of a partial closure notice (PCN) issued to the appellant by HMRC in respect of the tax year 2016/17. The PCN was issued on 30 December 2020 following an application by the appellant to the FTT (pursuant to TMA 1970, s 28A(4)) to compel HMRC to issue such a notice.  

The appellant appealed the closure notice to HMRC and simultaneously notified an appeal to