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Nicholas acted for HMRC in the successful defence of this highly complex civil tax appeal worth £28m. The hearing, which lasted 7 months, is the longest within the tribunal system. The case, which involved allegations of serious VAT fraud, was the first piece of government litigation to feature electronic preparation and presentation of evidence. It gave rise to a number of leading authorities, all in favour of HMRC, including on the admissibility of opinion evidence in tribunal proceedings and of material obtained pursuant criminal mutual legal assistance.