A brother and sister ran a restaurant. They rented the premises from their parents and sub-let it to the partnership. The partnership was dissolved in 2004. Other people then took over the restaurant and paid rent to the brother and sister and the parents.
HMRC opened enquiries into the tax returns of the brother sister and partnership for the year ended 5 April 2005. They subsequently issued notices under TMA 1970 s 19A(2).
The brother and sister appealed saying that some of the information had been supplied and the rest was not reasonably necessary. The partnership also appealed on those grounds.
The Special Commissioner said that the issue relating to s 19A notices was whether HMRC were entitled to issue the notices in the terms that they were framed rather than whether they had been complied with. The precise wording of the notice was important.
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