In R (oao Reid and Emblin) v HMRC; Reid and Emblin v HMRC [2020] UKUT 61 (TCC) (3 March 2020) the Upper Tribunal (UT) upheld the decision of the First-tier Tax Tribunal (FTT) that notices provided to individual members of a partnership pursuant to TMA 1970 s 28B(4) (a partner notice) are not closure notices. The UT also dismissed the taxpayers’ claim for judicial review (JR) of HMRC’s decision to issue accelerated payment notices (APNs).
On the closure notice issue the taxpayers argued that the closure notices issued to them relating to their individual tax returns were invalid because HMRC had already closed their enquiries by the partner notices and amendments made in those closure notices to disallow the taxpayers’ losses incurred outside their participation in the partnership (and therefore not covered in the...
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In R (oao Reid and Emblin) v HMRC; Reid and Emblin v HMRC [2020] UKUT 61 (TCC) (3 March 2020) the Upper Tribunal (UT) upheld the decision of the First-tier Tax Tribunal (FTT) that notices provided to individual members of a partnership pursuant to TMA 1970 s 28B(4) (a partner notice) are not closure notices. The UT also dismissed the taxpayers’ claim for judicial review (JR) of HMRC’s decision to issue accelerated payment notices (APNs).
On the closure notice issue the taxpayers argued that the closure notices issued to them relating to their individual tax returns were invalid because HMRC had already closed their enquiries by the partner notices and amendments made in those closure notices to disallow the taxpayers’ losses incurred outside their participation in the partnership (and therefore not covered in the...
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