In R (oao Lunn) v HMRC (and related application) (QB – 16 February) HMRC wrote to an unqualified accountant (L) in 2008 expressing significant concerns about the accuracy of the returns which he and a company (C) of which he was the controlling director was submitting. In 2009 HMRC’s Criminal Investigation Unit began a criminal investigation of L. They formed the conclusion that L ‘had systematically committed fraud’. In June 2010 HMRC applied for and were granted search warrants under the Police and Criminal Evidence Act 1984. Later that month L and his son were arrested on suspicion of cheating the public revenue contrary to common law false accounting and offences contrary to the Fraud Act 2006 and were interviewed under caution in the presence of a solicitor. They declined to answer most of the questions. In November 2010 HMRC terminated L’s...