Commentary

I11.336 Procedure at appeal hearing

IHT, trusts and estates

I11.336 Procedure at appeal hearing

I11.336 Procedure at appeal hearing

The Tribunal has considerable flexibility with regard to the procedure at the hearing. With regard to Basic appeals, the hearing is likely to be conducted informally. Directions may be made which affect the way in which the hearing is conducted, for example the Tribunal may direct that HMRC's representative should open the case even though the burden of proof falls on the appellant, particularly where the appellant is unrepresented.

The procedure before the First-tier Tribunal will most likely accord with standard court procedure. This is consistent with the fact that the procedural rules strongly echo the

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