In W Tinkler v HMRC [2018] UKUT 73 (13 March 2018) the UT found that by informing his named agent HMRC had duly given notice to the taxpayer of its intention to open an enquiry.
Mr Tinkler argued that the closure notice he appealed against was invalid because HMRC had never validly opened an enquiry into his tax return as HMRC had failed to give notice of its intention to enquire into the return to Mr Tinkler within the time allowed. HMRC contended that they had given notice to Mr Tinkler by two methods either of which was sufficient: posting the letter to Mr Tinkler; and sending a copy of the letter to BDO his accountants.
There was no dispute that BDO had received a copy of the notice of enquiry with a covering letter in July 2005. There was also no doubt that BDO...
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