I was struck by comments made by a Judge in a QBD Planning Court decision, criticising the claimant’s Solicitors for producing over 2,000 pages of largely irrelevant material! Then, having directed the parties to put together a ‘core bundle,’ the most significant points were tucked away in paras 76 and 77 of the skeleton.
I see lots of taxpayer arguments against HMRC, and vice versa. Sadly, so many fail to highlight the clear issues at stake.
Are you arguing legal statute, or the implication of case law, or simply the issue of facts? Make it clear, assuming the person reading the document has had no prior knowledge of the dispute.
The same principles apply to any correspondence with HMRC. Make it abundantly what you are arguing.
I agree with the Judge’s comment here in relation to VAT as well as Planning: