I've no experience of such appeals, just thoughts, I'm afraid, from when I used to manage an IB section. The case law on de minimis is mainly ancient, but try CIB 5298/1997 and CIB 3507/2003. If she and her husband were in a self-employed business partnership then profit and loss accounts from the date her partner took over the pub may also assist, as it will show salaries paid and accountancy fees, thus supporting her lack of involvement in the franchise. :~)
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