80% of cases are won by HMRC?

From C3 :

(… ) “The claim of an 80% pinocchiosuccess rate in all tax avoidance cases has been the bedrock upon which HMRC has justified the need for the introduction of APNs and FNs. However, after looking closely at the cases which form this percentage we must conclude that this justification is tragically flawed with a distinct lack of correlation between the arrangements in which the vast number of taxpayers have participated and those cases which progressed to the tribunal stage in the selective period that HMRC used as their statistical base”

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