Administration and appeals: Application for closure notice
In HH Collinson v HMRC (TC00470 – 6 May) an individual (C) claimed that he had made a tax loss of more than £400 000 in 1998/99 as a result of certain transactions in securities. In January 2001 the Revenue began an enquiry into C's return.
In September 2009 C applied to the First-Tier Tribunal for a closure notice. The Tribunal granted his application and directed that HMRC should issue a closure notice within 30 days. Judge Shipwright observed that 'nine years is a considerable time to wait to know whether a Government Department will or will not allow your claim.
If the claim is denied it is not until a closure notice has been issued that an appeal can be lodged. It could be some time then before the case is heard and a decision reached. The longer the period...
