Estoppel in tax disputes: In A Cattrell v HMRC [2024] UKFTT 67 (TC) (16 January 2024) the FTT dismissed the taxpayer's appeal against the validity of HMRC's closure notice in respect of an enquiry into the taxpayer's self-assessment return (which had included participation in a gilt strip scheme). The scheme was implemented as far as back 2003/04 and perhaps not surprisingly a copy of the enquiry notice said to have been issued by HMRC could not be located. But the FTT held that all of the evidence pointed to the fact that an enquiry must have been opened. The taxpayer’s appeal was therefore unsuccessful.
However despite finding the notice and enquiry was valid and therefore dismissing the taxpayer's appeal the FTT went on to consider whether had it not confirmed this validity would the taxpayer have been estopped from relying on any invalidity....
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