INCOME TAX – determination under s 28C TMA 1970 – whether right of
appeal to the First-tier Tribunal against such a determination – appeal
struck out by First-tier Tribunal on grounds that no such right – whether
strike-out decision correct – construction and effect of s 197 FA 1994 –
whether TMA 1970 forms part of “the Tax Acts” – no – held no such right
of appeal – appeal from First-tier Tribunal against striking out dismissed.