R & S Thomas v HMRC (No. 2)

The case of R & S Thomas v HMRC (No. 2) (TC02618 – 4 April) is the latest instalment in a long running saga. A partnership traded from 1998 to 2002 when it sold its business to a limited company. HMRC began an investigation into the partnership. In May 2004 the partners agreed to pay HMRC £525 000 in respect of tax interest and penalties. In October 2004 an inspector wrote to the partners stating that he intended to open an enquiry into their returns and the partnership return for the year ending 5 April 2003. The partners appealed to the General Commissioners who held that the effect of the May 2004 agreement was that it was not possible for the Revenue to open a further enquiry for the year ending April 2003. In R (oao HMRC) v Berkshire...