1. Do I have an appealable decision?
There are numerous decisions from HMRC which carry a right of appeal. The most common decisions which can be appealed include the following:
(i) a conclusion stated or amendment made by an enquiry closure notice issued under TMA 1970 s 28A or s 28B or FA 1998 Sch 18 para 34;
(ii) an amendment of a self-assessment made by HMRC during an enquiry in order to prevent a loss of tax under TMA 1970 s 9C or FA 1998 Sch 18 para 30 – often referred to as ‘jeopardy amendments’;
(iii) an amendment of a partnership return made under TMA 1970 s 30B (loss of tax discovered); or
(iv) an assessment to tax which is not a self-assessment for example a ‘discovery assessment’ issued under TMA 1970 s 29 or FA...
