Is fighting HMRC just simply too costly?

HMRC have finally concluded that after 13 years of litigation over the Marks and Spencer teacakes case, that enough is enough!

I recently managed to persuade HMRC complaints team, after a two year battle, to back down and pay up. It has been a relentless battle, made difficult that knowing the more HMRC dig their heels in, the more the client’s costs merely escalate without a result. The persistence did pay off eventually and I did manage to get the clients costs reimbursed, but as with all these cases, there is never a guarantee on such a positive outcome.

It did get me thinking that, if 2 years arguing one relatively small issue (although financially large for the client concerned) seemed a long time, and HMRC will clearly argue for longer( even up to 13 years!), has anyone else found themselves ‘giving-up’ as arguing is costly and time consuming – is anyone as cynical as I am that they believe some Officers use ‘dragging’ it out as a technique to hope you will back down first due to costs?