Martin v Revenue and Customs (Income Tax – Closure Notice and Amendment To Return): FTTTx 2 Dec 2019

INCOME TAX – closure notice and amendment to 2012-2013 return – HMRC’s disallowance of partnership losses for relief against other income on the basis he was a partner in Great Marlborough LLP which was not trading on a commercial basis with a view to profit – HMRC’s issuing of two letters purporting to open an enquiry – HMRC’s failure to open an enquiry into the partnership return – number of procedural challenges – validity of HMRC’s section 9A TMA 1970 enquiry – validity of HMRC closure notice – appeal dismissed

Citations:

[2019] UKFTT 710 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 24 November 2022; Ref: scu.646933