In the Court of Appeal, Rebecca Sheldon acted on behalf of the Appellant, Mr Oisin Fanning. Mr Fanning previously appealed unsuccessfully to the First-tier Tribunal and then to the Upper Tribunal, against HMRCs disagreement to his SDLT analysis, which resulted in the issuance of a discovery assessment on 28 March 2014. The SDLT in question related to a property with a purchase price was £5,200,000 at that time the transaction would ordinarily have been charged SDLT at a rate of 5%. However, Mr Fanning filed a SDLT return on the basis that he had no liability to pay this sum as a result of another transaction that Mr Fanning entered on the same date. For more information on this case, please view the judgment.