In Bilal Khan v HMRC [2014] UKFTT 1050 (19 November 2014) the FTT refused an application for a closure notice on the ground that the length of the enquiry was due to the taxpayer’s fault.
Mr Khan had submitted his tax return on 24 January 2012 and HMRC had opened an enquiry on 26 July 2012. It had taken the taxpayer until June 2013 to provide HMRC with bank statements relating to previously undisclosed bank accounts. The statements showed large deposits and withdrawals; and HMRC had requested evidence of the source of the deposits and an explanation of the nature of the withdrawals. Mr Khan (via his agent) had only supplied part of the information. On 10 May 2014 Mr Khan had applied to close the enquiry.
The FTT refused the application noting that it had reasonable grounds for doing so. Mr Khan had not provided HMRC...