Wammee Holdings Ltd v Revenue & Customs (COSTS - Rule 10 - Appellant and Respondent each applying for a costs order) [2020] UKFTT 240 (TC)

First Tier Tax Tribunal consideration of cross-appeal on costs.  Tribunal considered whether HMRC's refusal to mediate was unreasonable.  Judge considered whether ADR would have had reasonable prospect of success and concluded that at the time it was unlikely - the Appellant bore the burden to prove unreasonable conduct and had failed to discharge that burden.