In Greenoaks Pharmacy Ltd v HMRC (TC01118 – 5 May) HMRC began an enquiry into a company (G) which operated several retail pharmacies.
On 23 July 2009 they issued ‘jeopardy amendments’ to G’s self-assessments increasing its tax liability by more than £1 000 000. On 21 August G’s accountant sent HMRC a fax stating that he would ‘be sending appeal and postponement applications to those amendments in due course’. The HMRC officer dealing with the case treated this as an expression of intention rather than a formal appeal.
Subsequently HMRC began action to collect the debt and G sent a further fax indicating that it was appealing against the amendments. HMRC treated this as an application to make a late appeal and rejected it on the grounds that there was no reasonable excuse for the delay.
G lodged...
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