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P Nichols and C French v HMRC

In P Nichols and C French v HMRC [2016] UKFTT 155 (4 March 2016) the FTT ordered the issue of a closure notice in the complete absence of evidence from either side.

Mr Nichols had applied for closure notices of enquiries relating to several tax years. The FTT had directed that these applications should be grouped under a single reference and heard together with Mr French’s application for a closure notice.

The hearing was listed for 1 March 2016 and HMRC had tried to adduce evidence at 19:17 on 29 February. The FTT refused to admit it as there was insufficient time for the appellants to consider it.

TMA 1970 s 28A(6) requires the tribunal to direct that a closure notice be issued within a specified period ‘unless satisfied that there are reasonable grounds’ for not doing so. As a result of the exclusion of HMRC’s evidence ...

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