Theodore Wallace

Decision released 23 May 2006

Closure notice – Application for direction to close enquiry into return – Company – FA 1998 Sch 18 para 33 – Direction for closure within four months


A special commissioner granted an application for a direction for closure notices to be given in respect of enquiries into the taxpayer company’s tax returns for the years ended 31 January 2003 and 2004 where the Revenue had failed to discharge the burden of establishing reasonable grounds for not giving a closure notice within a specified period.


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