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The hearing took place over on 22 November 2021. The form of the hearing was video attended by all parties.  A face to face hearing was not held as a hearing in a court room was not felt necessary or desirable bearing in mind the ongoing pandemic.  We had skeleton arguments from both parties, a documents bundle and an authorities bunds
Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� As such, the hearing was held in public.
Mr D Corps, litigator of HM Revenue and Customs� Solicitor�s Office, for the Respondents
             This is an appeal out of time against the decision to issue a Notice of VAT Assessment under section 73 of the Value Added Tax Act 1994 totalling �92,036.00.
             The assessment relates to VAT the Respondents considered to have been due from the Appellant on the deemed supply of assets at deregistration, based on information provided by the Appellant.
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