Kenny Grant, 50, and Ryan Abbott, 34, directors of KNR Flooring Ltd, were in dispute with HMRC over the 2020-21 and 2021-22 tax years. The appeal related to their CJRS claims made during the many months the furlough payments were available to some workers during the pandemic.

HMRC was adamant the amount of money paid to KNR Flooring through the CJRS during the pandemic exceeded the amount the company was entitled to for two directors who were the sole employees.

In 2020 the company had £37,442 paid to it through the CJRS, and £12,432 the year after this through 15 claims.

By August 2021 HMRC officer Barrett opened a compliance check into the company to establish whether it had claimed the correct amount in CJRS payments. Barrett asked for details of how the claims were calculated, taking until March 2022 to ask the accountant of the company how the monthly payment was established.