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Heard on: 25 and 26 May 2022 with additional written submissions received in August and September 2022
For the Appellant:�������� Michael Firth of counsel instructed by Silver Levene LLP
For the Respondents: �� Martin Priestley, litigator, of HM Revenue and Customs' Solicitor's Office
              Prior to December 2014 Ameeka Patel and Rajiv Ruwala (the � partners �) carried on a dental practice business (the � business �) in partnership (the � partnership �) from premises (the � premises �) at 2 Green Walk, Dartford.
             2 Green Smile Limited (the � company �), which had been incorporated earlier in 2014 and which changed its name in or around September 2014, succeeded to the business, and its accounts record that it started trading on 1 December 2014, providing dental services in succession to the partnership.
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