These latest figures indicate an alarming trend in that - when challenged - HMRC are incorrect more than they are correct.
Whilst it would not be fair to draw a parallel with HMRC decision making generally, it should serve as a reminder to check HMRC's figures carefully and to query any point of law they may raise as to its accuracy.
In 2015-16, UK taxpayers were successful in challenging 57 percent of decisions and enforcement actions taken by HM Revenue and Customs (HMRC), according to research by international law firm Pinsent Masons. Pinsent Masons said that the figure relates to "reviews" requested by taxpayers, whereby HMRC is asked to reconsider its decisions and put forward an explanation. Reviews are carried out by HMRC staff who are independent of the teams who worked on the original case.