The appellant, Louis Daniel Moore, appealed to the FTT against closure notices issued by HMRC on 19 December 2016 amending his income tax returns, for the tax years 2008 to 2010.

HMRC sent Moore a demand for additional income tax totalling £1,133,875.74 for his involvement as a minority shareholder of restricted stock units (RSUs).

On 7 March 2008, NYSE Euronext (NYSE) purchased Wombat Financial Software Inc through a sale and purchase agreement. At the time, Moore was a minority shareholder and employee.

NYSE authorised a grant of 151,639 restricted stock units to Moore and in each of the relevant years, shares in NYSE Group Inc were vested to him.