This case concerned a costs application in a basic category case involving an Accelerated Payment Notice (APN). HMRC had failed to issue a closure notice, resulting in a delay and the taxpayer having to bring proceedings. The issue was whether HMRC had acted unreasonably in defending the proceedings, such that a costs order should be made under Rule 10(1)(b) of the Tribunal Rules. The Tribunal held that HMRC had not acted unreasonably in defending the proceedings. The Tribunal further held that HMRC’s conduct before the proceedings were issued was not determinative of whether its conduct in the proceedings was unreasonable.