Interesting stuff on tough luck potential double taxation in para 127 and on mislabelling at para 63 et seq. Taxpayer lost badly through bad implementation mainly (the sale contract being found void - never a good start*). Also, it may be too late to get their POAT refunded. What a mess (possibly per para 22 they can sue the adviser and reclaim the SD - assuming they don't appeal)!
*What’s really crazy is the tremendous amount of ink spilt on pages and pages on complex IHT analysis on these schemes like in the link below, yet they overlook the basics causing the sale to be void and the scheme failing therefore even before it's got to the first IHT hurdle (and worse still none of that ink seems to cover s163 identified as a potential double IHT problem had the contract not been void since the deceased nevertheless retained beneficial ownership of the property under the relevant BO case law thanks to the failed attempt to also avoid SD)!
So the judge actually did the taxpayer (and his advisers) a favour in finding the contract void (as that way potential double IHT was avoided). What a joke!