M v Revenue and Customs: FTTTx 19 Apr 2018

Income Tax/Corporation Tax : Assessment/Self-Assessment – INCOME TAX – Self-Assessment returns – enquiry into 2015-16 and prior years from 2011-12 to 2014-15 – applications for closure notices – s 28A Taxes Management Act 1970 – whether enquiry being related to a company relevant – whether tribunal has jurisdiction to consider complaints against the conduct of HMRC officers – whether new evidence admissible at the stage of closing submissions – whether reasonable grounds for not issuing closure notices; yes – quality of information provided – taxpayer’s co-operation and extent of disclosure – risks identified in taxpayer’s income and capital profile – third-party information notices approved by the Tribunal – whether period for the issue of notices can be specified; no – applications refused
[2018] UKFTT 228 (TC)
Bailii
Taxes Management Act 1970 28A
England and Wales

Updated: 22 October 2021; Ref: scu.609281