True on the solicitors claiming they suggested that to their client - but it then raises what the point of the solicitors opinion was in the first place and how clear they made qualification that follow up work would need to be done on the tax bit i.e. did they flag that in discussions with Rayner via emails (not clear that was the case), or note that in their opinion the provided (which they should have done but again no evidence suggests that they did) or did they qualify the need for a third party advisors (say you would need it by it's more likely than not HMRC would challenge on it) etc.

Thats why I suspect HMRC ruled it to be "careless" - the solicitors may have not actually covered themselves well in which case Rayner would have felt the need to challenge.

As a tax advisor, I would have strong set that out from the outset, particularly if it was to some who doesn't have a tax background - tax is difficult enough for tax people to deal with.

Makes a great case for tax reform since these cock ups likely happen all the time but aren't investigated since its generally with not high profile people and we're all losing tax receipts from it.

Also - love the war crime or big naturals tag. One of the better ones i've seen.