Mark Wallace was a member of three LLPs which traded in the UK, however, he was not a UK tax resident, and the income for the LLPs came mostly from rentals overseas. He was, and still is, a Swiss resident.

Because of this Wallace believed his share of the profits was not subject to UK tax.

HMRC did not share this point of view though, opening closure notices into Wallace for the 2015/16, 2016/17, 2017/18 and 2021/22 tax years for a total of £447,459.65.

In total Wallace was a member of nine film partnerships that are all now dissolved, but the closure notices and his appeal revolved around just three; Cherwell Films, Rose Film Partnership, and The Close Film Sale and Leaseback.