[2026] UKUT 00284 (TCC) Richard Warner v The Commissioners of His Majesty's Revenue and Customs
Upper Tribunal Tax and Chancery decision of Judge Poole and Judge Greenbank on 28 July 2026.
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Stamp duty land tax – claim for multiple dwellings relief not made in land transaction returns – subsequent out of time request to amend the returns to claim the relief rejected due to their lateness – whether the request should have been treated as a valid claim for overpayment relief – whether HMRC had given notice of enquiry into the appellant’s claim and closed their enquiry – whether an appealable decision had been made – Case A and Case C in paragraph 34A Schedule 10 Finance Act 2003 also considered