TC09615 - [2025] UKFTT 01016 (TC)

The Closure Notice for 2011-12 had the same “conclusion” as that for the previous year, but after the paragraphs set out at §11 above, it included the words:

“You should note that, depending on the exact nature of any convention put forward on behalf of you [sic] to the contrary, HMRC may wish to advance additional or alternative grounds in support of an amendment being made to your personal return.”

Under the heading “how this notice amends your Self Assessment tax return”, the Closure Notice said that Mr Tinkler’s net loss from his self-employment had decreased from £2,664,640 to £508,356, and the loss set against other income of the same year had decreased by the same amount.

As in 2010-11, the Closure Notice directed Mr Tinkler to the “schedule” which provided “full details of the figures amended including stock valuations”. The attached documents were of the same nature as in 2010-11, and the covering letter was identical, other than in relation to the amounts.