Chan v Revenue & Customs [2011] UKFTT 84 (TC) (25 January 2011)

Chan v Revenue & Customs [2011] UKFTT 84 (TC) (25 January 2011)

The Tribunal found reasonable grounds for not issuing a closure notice, as relevant information and documentation had not been provided, and delays were not sufficient to render the enquiry prolonged or protracted.

Citation
[2011] UKFTT 84
Parties
Appellant: Wai Yau Chan; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
25 January 2011
Procedural Posture
Tax Appeal / Application for Closure Notice
Outcome
Application for closure notice refused
Legal Topics
Income Tax, Corporation Tax, Closure Notice, Schedule 36 Notice, Self Assessment Enquiry
Tax Law Income Tax Corporation Tax Closure Notice Schedule 36 Notice Self Assessment Enquiry

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Parties

Wai Yau Chan

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Closure Notice

Legal Issues

  1. 1 Whether there are reasonable grounds for not issuing a closure notice under section 28A of the Taxes Management Act 1970

Ratio Decidendi

The Tribunal found reasonable grounds for not issuing a closure notice, as relevant information and documentation had not been provided, and delays were not sufficient to render the enquiry prolonged or protracted.

Court Disposition

Application for closure notice refused

Orders

  • No closure notice to be issued
  • No order as to costs