The second type - deliberate stupidity

the VAT legislation is pretty clear that club memberships can have both vatable and non-vatable elements. The element relating to entrance to matches must have been vatable, that is described in words of one syllable in the VAT regulations, so the argument surely must have been about what value of membership to attribute to the non vatable benefits package and the match entrance element. The Vatmans default position will have been a split of 0/100% on the basis that it was a marketing incentive by the club not the purpose of membership. I would have sought the advice of a VAT consultant after checking his PI insurance before witholding large amounts of VAT on the basis of such an assumption of the split.

i'd suspect the membership pack freebies and member only votes on things like naming stands and bars plus talk about making some bars member only (although only superficially implemented) were an attempt to give extra value to memberships in attempt to increase non vateable percentage.

It was a scam, nothing more. He tried to con the revenue, deliberately. This was never going to work.
We've had previous owners who f*cked up through stupidity and ignorance, this time it was just devious.

There are lots of companies which deliberately 'scam' the tax laws though, mainly big multi-nationals, pretending they don't do business in this country. I'm pretty sure there is a basic attitude, in many people - in big business or otherwise, that taking the P out of the taxman is fair game. In the accepted knowledge that the big beasts get away with it, it's hard to take a moral line when the, 'little people', try to get away with it. The law should work for all, imo.