[2009] UKFTT 333 (TC)

Richard Barlow (Chairman), Tony Hughes

Decision released 16 October 2009

Closure notice – disclosure of information by taxpayer materially complete – whether reasonable to delay while R & C Commrs make enquiries of third parties? – no (on the facts) – notice directed

  The tribunal agreed to make a direction requiring HMRC to issue a closure notice in respect of an inquiry into the taxpayer’s return within 45 days where HMRC had conceded that such a notice should be issued and could not be certain that any additional information it was seeking would be obtained if it was given further time.


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