TC09619 - [2025] UKFTT 01020 (TC)

It is for HMRC to establish that they opened a valid enquiry into the relevant tax years and then issued and served valid closure notice on the appellant. From the evidence that we have seen, they have established both. The appellant has not seriously challenged either the technical validity of the closure notices nor the amounts set out in them. We therefore find that the closure notices were valid and the amendments made by them were numerically correct.

The onus then is on the appellant to show that the amendments overcharge him. For the same reasons that we have given as regards his failure to establish an overcharge in relation to the discovery assessments, we are not satisfied that he has demonstrated that the closure notices and the amendments made by them overcharge him either.