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The Commissioners for Her Majesty’s Revenue and Customs v Woodgate


William Irwin represented HMRC in a claim against Jonathan Woodgate for a debt of over £960,000. The debt arose from various Accelerated Payment Notices (APNs) and Partner Payment Notices (PPNs) issued by HMRC under the Finance Act 2014.

In a judgment handed down on 3 May 2018, HHJ Mark Gargan – the Designated Civil Judge for Cleveland and South Durham – refused Mr Woodgate’s application to set aside a default judgment obtained by HMRC.

Applying the principle in O’Reilly v Mackman [1983] UKHL 1, [1983] 2 AC 237 the Judge held that it was not open to the Defendant to challenge the validity of the APNs or PPNs in the course of enforcement proceedings. Accordingly he held that the Defendant did not have a realistic prospect of successfully defending HMRC’s claim and should not be permitted to have the default judgment set aside.

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William Irwin

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