Income tax – Partnership. The 154 taxpayers issued judicial review proceedings, challenging the legality of partner payment notices given by the defendant Revenue and Customs Commissioners in the exercise of new powers under the Finance Act 2014. The Administrative Court, in dismissing the application, held that there had been no breach of natural justice and the decision to give the notices was neither unreasonable nor irrational. Further, there had been no breach of the taxpayers' legitimate expectations, or their rights under art 6 of the European Convention on Human Rights or art 1 of the First Protocol to the Convention.