Mr Bell challenges the UT’s determination that he is not entitled to see certain documents which are in the possession of HMRC and which HMRC wish to disclose to him. The documents arise out of HMRC’s investigation into the tax affairs of another taxpayer, Mr Mitchell. Mr Mitchell’s objection to the disclosure of at least some of those documents was successful in the FTT and UT. The issue for this Court is whether Mr Mitchell’s objections lie on solid ground and should be upheld. This appeal is brought with the leave of this Court