[2011] UKFTT 342 (TC)

Judge Peter Kempster (Chairman), Ms Gill Hunter

Decision released 20 May 2011

Corporation tax – closure notice applications – categorisation of proceedings as complex – loss relief group litigation order – in-time claims subject to statutory appeals procedure – group structure – no possibilities test – whether HMRC should give closure notices in respect of open enquiries – whether closure notice proceedings should be re-categorised as complex – Finance Act 2008, Sch. 18, para. 33 – Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, r. 23

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