The Court of Appeal has upheld the decision of the Upper Tribunal which found that the taxpayer did not meet the conditions for sideways relief for losses deriving from his farming business for the tax years from 2008 to 2012. The dismissed appeal means that the taxpayer now owes HMRC £587,140.21.

Ardeshir Naghshineh purchased Salle Moor Hall in Norfolk in 1995 with plans to make it a conventional working agricultural farm. He had no experience of running a farm and hired a manager to help him.