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A married couple applied to have HMRC enquiries into their affairs closed.
The issue arose as to whether HMRC had sent notices of enquiry under TMA 1970 s 9A.
It was agreed that a notice had been sent in respect of the wife’s 2004-05 tax return but not regarding anything else.
A letter from the civil investigation fraud team had been sent with regard to the taxpayers’ affairs but HMRC claimed that this was not a s 9A letter.
The wife argued that the letter should be regarded as such even though nothing in the letter specifically referred to s 9A.
The Special Commissioner accepted HMRC’s contention and said he therefore had jurisdiction over the wife’s 2004-05 return only.
With respect to this return he said there was no ground to issue a closure notice as there were unresolved questions relating to her income...
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