In the First-tier Tribunal, Rebecca Sheldon assisted Harriet Brown in representing the Appellant, Paul David Eveleigh on a pro-bono basis. This appeal challenged HMRC’s decision to issue an excise duty assessment in the sum of £121,666 arising from the import of 1,160 kg of tobacco from France into the UK. The court explored whether HMRC had discretion to decide not to issue an excise duty assessment where liability is not in dispute, and whether proportionality can be considered in relation to section 12 of the Finance Act 1994. For more information on this case, please view the judgment.