I work for a Government department who are involved in civil cases on a daily basis, I worked in their appeals department a few years ago and this is what I remember, I will share a bit of knowledge to hopefully help clear a few things up with the procedural side of things. HMRC have lost the First Tier Tribunal, they have appealed this decision but can only appeal if they think there has been an error in the way the law has been applied. This new hearing is only to assess the First Tier decision and can go one of two ways; there has been an error in law therefore the case will be sent to the