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CRC v M Mabbutt, Upper Tribunal (Tax and Chancery Chamber), 2 August 2017
Notice of enquiry into return
In January 2011 HMRC opened an enquiry into the taxpayer’s 2008-09 return on the basis that he had taken part in a tax avoidance scheme. Two letters were sent: one to the taxpayer and one to his agent. However because of a clerical error both letters referred to the year ended 6 April 2009. The latter referred to the arrangement that was registered under the disclosure of tax avoidance schemes (DOTAS) regime. HMRC concluded that a further £653 000 tax was due and issued a closure notice in July 2014.
The taxpayer appealed saying no enquiry had been opened because no valid notice of enquiry had been given. As a result there could be no valid closure notice. He said the enquiry notice had referred to his tax...
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