Once an officer has opened an enquiry, its progress to conclusion will depend on a wide range of variables including such diverse matters as:

the confidence and competence of both the officer and the practitioner;

the credibility of the client;

the chemistry of the parties;

the client's previous tax history;

the nature and quality of any information held by HMRC;

the reliability of the client's records;

the availability of evidence to assist the quantification of undeclared liability;

the nature and quality of any disclosures by the client;

the underlying reason for any previous under-recognition of profits or gains;

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