Leonard Toye, 71, took HMRC to the FTT on 28 January 2025 to appeal against VAT assessments which were originally handed to his company, Black Wolf. Toye has since stood down from the company and Black Wolf is being liquidated.

Toye is a master locksmith and had control of 75% of the company according to Companies House. However, evidence brought forward by Toye showed he owned 50%, his wife owned 1%, and his nephew, Darren Chaston, owned the remaining 49%. This was regarded as ‘irrelevant’ information by Judge Nigel Popplewell.

Black Wolf was a mobile locksmith business, operating out of Toye’s house. To do this Toye bought three BMW motorbikes and a van as he offered a ‘fast reaction’ response time to customers in London. These motorbikes were at the centre of HMRC’s case as the VAT had been recovered on all three, as well as the clothing and tool carrying kits attached to the motorbikes.

HMRC