Bryan v Revenue and Customs (INCOME TAX - enquiries into tax returns) [2026] UKFTT 743 (TC) (19 May 2026)

Bryan v Revenue and Customs (INCOME TAX - enquiries into tax returns) [2026] UKFTT 743 (TC) (19 May 2026)

HMRC has reasonable grounds for not issuing closure notices because material information regarding client account transactions, disbursements, work in progress methodology, and expense fluctuations remains outstanding and is necessary for a fair and accurate closure notice. The information sought is not privileged and is proportionate to the enquiry. Issuing a closure notice now would be premature and potentially unfair to both parties.

Citation
[2026] UKFTT 743
Parties
Applicant: Mr Paul Bryan; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
19 May 2026
Procedural Posture
Income Tax Application for Direction to Issue Closure Notice / First Tier Tribunal (tax) Decision on Application
Outcome
Application dismissed
Legal Topics
Income Tax Enquiries, Closure Notices, Tribunal Procedure, Legal Professional Privilege, Tax Return Amendments
Tax Law Income Tax Enquiries Closure Notices Tribunal Procedure Legal Professional Privilege Tax Return Amendments

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 8 Party arguments 2 Amounts and remedies 9
Sign in to unlock

Parties

Mr Paul Bryan

Applicant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Application for Direction to Issue Closure Notice / First Tier Tribunal (tax) Decision on Application

Legal Issues

  1. 1 Whether HMRC has reasonable grounds for not issuing closure notices for the applicant's 2017 and 2018 self-assessment tax returns
  2. 2 Whether information requested by HMRC is necessary and proportionate
  3. 3 Whether client account bank statements are privileged

Ratio Decidendi

HMRC has reasonable grounds for not issuing closure notices because material information regarding client account transactions, disbursements, work in progress methodology, and expense fluctuations remains outstanding and is necessary for a fair and accurate closure notice. The information sought is not privileged and is proportionate to the enquiry. Issuing a closure notice now would be premature and potentially unfair to both parties.

Court Disposition

Application dismissed