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Taking a bite out of the Revenue!
Key points
- Working with various parties including the software provider to ensure the return is completed correctly.
- HMRC’s reasons for implementing the 20-year enquiry limit.
- Meaning of ‘deliberate’ has changed over the years.
- Importance of taking the correct steps when handling enquiries and respecting the legislation.
The title of this article was something an inspector of taxes said to me after the report of our first win at the First-tier Tribunal was published in Taxation (‘No deliberate intent’ 21 November 2016 page 6).
The inspector was one of the last few classically trained inspectors I can remember dealing with at HMRC and is quite on point regarding this case.
I am sure he will be reading this article and will not mind me saying that he was practical and sensible in his handling of a very long case which we had both been working...
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