,

Archer v. HMRC [2023] EWCA Civ 626

Delaying payment of £1.4M to HMRC was ‘not reasonable or responsible’ while waiting for permission to appeal from the Supreme Court after a ‘unanimous and compelling judgment of the Court of Appeal told him in clear terms that he owed the tax’: https://caselaw.nationalarchives.gov.uk/ewca/civ/2023/626