Normal procedure
Normal procedure
Over a number of years the taxpayer failed to co-operate with HMRC with regard to enquiries into his self-assessment tax returns. He did not produce documents when requested so HMRC issued a notice under TMA 1970 s 19A requiring him to produce them. He appealed to the General Commissioners but they dismissed the appeal because of the large discrepancy in his accounts. HMRC subsequently imposed a penalty for failure to comply with the s 19A notice against which the taxpayer appealed to the Special Commissioner. The appeal and the notice were found to be defective by the Commissioner. The notice was withdrawn but another notice of determination of daily penalties for the continued failure to comply with the s 19A notice was issued under s 97AA. The taxpayer appealed.
The Special Commissioner found that until the documents required by HMRC had been produced...
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