Patel and Another v Revenue and Customs: FTTTx 5 Apr 2018

Income Tax/Corporation Tax : Assessment/Self-Assessment – INCOME TAX- preliminary issue – ‘voluntary returns’ – no notice given by HMRC under s.8(1) Taxes Management Act 1970 (TMA) requiring a taxpayer to file a return – HMRC treating returns as made under s 8 TMA – enquiry commenced under s. 9A TMA – closure notice issued under s 28A TMA – whether returns made under s 8(1) TMA and therefore whether enquiry and closure notices valid – held: no – scope of care and management powers under s1 TMA and s5 Commissioners of Revenue and Customs Act 2005 (CRCA) – scope of ancillary powers under s9 CRCA

Citations:

[2018] UKFTT 185 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 14 April 2022; Ref: scu.609285