First-tier Tribunal – Hearing of taxpayers appeals’ – Allegations of
dishonesty relating to evidence adduced by the taxpayers on a particular
issue – Burden of proof – Whether necessary for HMRC to plead the
allegations – Adjournment refused by the FTT, and case management
directions given for future conduct of the hearing – Whether the FTT erred
in law – Taxpayers’ appeal against refusal of adjournment dismissed –
HMRC’s appeal against case management directions allowed.