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1. The applicant, Mr Craig Kay, applies to the Upper Tribunal (Tax and Chancery) (鈥淯T鈥�) for permission to appeal against the decision, made on the papers, of the First-tier Tribunal (Tax Chamber) (鈥渢he FTT鈥�) released on 12 October 2023 (鈥渢he FTT Decision鈥�) and published as Kay v HMRC [2023] UKFTT 861 (TC).
2. Mr Kay renewed his application to the UT. I had previously refused permission to appeal on paper in my decision of 28 June 2024 sent to the parties. This is my decision following the oral renewal of the application heard on 8 October 2024. Mr Kay represented himself. HMRC attended as observers.
3. The FTT Decision concerned Mr Kay鈥檚 appeal against a closure notice in relation to the amount of relief on a gift of shares on 2 April 2004 in a company, Access Intelligence Plc, which Mr Kay had made to a charity. The only issue before the FTT was the market value of the shares at the time of the gift. The FTT preferred HMRC鈥檚 valuation of 9.44p per share rather than Mr Kay鈥檚 valuation of 42.5p per share, reducing the claimed amount of relief Mr Kay had claimed of 拢80,750 down to 拢17,936.