Tinkler v HMRC

In 2005 HMRC sent a letter opening an enquiry into the taxpayer’s return. The letter was sent to an old address rather than the address which he had included in the return. A copy of the letter was sent to his agents BDO. The enquiry continued through correspondence and phone calls between HMRC and BDO culminating in the issue of a closure notice in 2012. The taxpayer appealed against the notice and subsequently amended his notice of appeal to contend that HMRC had failed to give a valid notice of enquiry because the enquiry notice was not sent to his last known...