Following the article in Issue 772 Bob Ramage Tax Department Slaughter and May discusses RK Carvill v Frost. Bob was the person dealing with the Revenue's investigation and the ensuing litigation
In the hearing on RK Carvill v Frost lasting four days before two Special Commissioners the taxpayer was awarded costs on the basis of the Revenue's wholly unreasonable conduct in the terms of Regulation 21(1) Special Commissioners (Jurisdiction and Procedures) Regulations 1994. A finding of this nature is as the Special Commissioners noted 'extremely rare' (particularly one imagines where as in this case the taxpayer's costs amount to some £1.5 million). Apart from the rarity of such a finding the case throws up some interesting side issues...
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Following the article in Issue 772 Bob Ramage Tax Department Slaughter and May discusses RK Carvill v Frost. Bob was the person dealing with the Revenue's investigation and the ensuing litigation
In the hearing on RK Carvill v Frost lasting four days before two Special Commissioners the taxpayer was awarded costs on the basis of the Revenue's wholly unreasonable conduct in the terms of Regulation 21(1) Special Commissioners (Jurisdiction and Procedures) Regulations 1994. A finding of this nature is as the Special Commissioners noted 'extremely rare' (particularly one imagines where as in this case the taxpayer's costs amount to some £1.5 million). Apart from the rarity of such a finding the case throws up some interesting side issues...
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")