At Churchill Tax most cases are resolved by reaching a negotiated financial settlement. However, in a few cases the two sides are not able to reach agreement. Sometimes the dispute will be the interpretation of some tax legislation, where, after both sides have put forward their views in often protracted and detailed correspondence, neither side has been able to persuade the other side that they are right. In many cases the issue will be whether there is sufficient evidence to take a particular view, for example to support unexplained deposits in a private bank account held by the proprietor of a business where HMRC want to treat these as unrecorded business takings. 
Where the taxpayer, or the agent acting, is unable to agree with the HMRC officer carrying out the tax investigation, the taxpayer can request a review of the case by an independent officer from within HMRC. Experience suggests that it is rare for this review to lead to a complete change of mind by HMRC, but it does sometimes happen.
Most cases begin by going before the First Tier Tribunal; both sides have the right to lodge an appeal against the decision, but only where it can be shown that the First Tier Tribunal has erred in a matter of law; the First Tier Tribunal makes the final decision on questions of fact. If an appeal is allowed it is usually heard by the Upper Tribunal. In some circumstances further appeals can be made to the Court of Appeal or even the Supreme Court.