You should bear in mind in setting out the case for HMRC that
you are seeking to modify the impression created in the minds of
the Commissioners by the opening statement for the appellant and to
emphasise and bring into special prominence the facts and
contentions which support HMRC case and tell against the case
presented for the appellant.
You should be neither unduly hurried nor unnecessarily
prolonged. You should watch the reaction of the Commissioners and
their Clerk as to the degree of attention they are giving to you
and if they are trying to make full notes or write down what you
say, then your pace should be slow enough to enable them to do so.
The Special Commissioners will try to take down in long-hand all
you say and therefore you do have to conduct the case fairly
slowly.