TC09593 - [2025] UKFTT 00892 (TC)

Given our conclusion on this point, we do not need to deal with HMRC's other arguments, which are either focussed on remediation of the Defective Notice using section 114 of the Taxes Management Act 1970; or which seek to argue that engagement with the Appellant's previous agent, PWC, who did not challenge the notice of enquiry for want of compliance with section 12AC, raised an estoppel by convention operating so as to prevent the Appellant raising the point about a defective notice: see Tinkler v HMRC [2021] UKSC 39.