HMRC really messed up here in simply not stating NM was a promotor in their application - see para 77.
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10913/TC0...
Well done to the Respondent’s counsel who sadly died recently - along with one of their witnesses.
See: https://www.accountancydaily.co/ftt-decision-defines-dotas-scheme-promoter
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"Well done to the Respondent’s counsel who sadly died recently - along with one of their witnesses. "
I always thought HMRC were bad losers but that's over the top.