AH0955 - Commissioners’ Hearing: The case for HMRC: Setting out the case


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.