TC09588 - [2025] UKFTT 00876 (TC)

In summary Mr McKee submitted as follows:

Although, at face value, it appears that the appellant is appealing against the closure notices, it is equally apparent from the grounds of appeal and the appellant’s skeleton argument that he is, in fact, challenging the balance of his self-assessment account. This is not an appealable decision within section 31 TMA.

The only elements of the closure notices which can be appealed are those under the headings “Our conclusion”, “Reason for our conclusion” and “How your tax return has been amended”.