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HMRC opened an enquiry into the taxpayer's 2003-04 tax return. Various documents were called for and agreement was reached on expenses. The accounts figures remained in dispute and eventually, because of the taxpayer's lack of co-operation in providing information, HMRC issued a closure notice under TMA 1970, s 28A and amended the return. The taxpayer's adviser appealed on his behalf. However, having had no response from the taxpayer, the adviser ceased acting for him. The taxpayer was told of the appeal hearing before the Special Commissioner, but did not respond or attend.
The Special Commissioner said that it was for the taxpayer to show that he had been overcharged by the self assessment as amended after the enquiry. He had not provided any further information or evidence to show that the figures were wrong.
The taxpayer's appeal was therefore dismissed.
Bryant (SpC 623)
