TC09630 - [2025] UKFTT 01071 (TC)

On 7 December 2018, Officer Fowler sent Mr Cooke a letter saying she was about to close her SA enquiries into the three years 2013-14 to 2015-16. She attached computations of the extra tax she had decided was due, including profits from land and property relating to rental income. The extra tax was £12,806.27; £12,253.90 and £7,578.35 respectively. Part of that tax related to other errors or omissions identified in Mr Di Lellio’s SA returns.

On 30 January 2019, Officer Fowler issued closure notices for those three years, together with amendments to Mr Di Lellio’s returns, on the basis set out in her letter of 7 December 2018. Her covering letter began as follows (our emphasis):

“Further to my letter dated 7 December 2018. As I have not received any communications indicating that my best judgment proposals should be revised, I have issued closure notices and amendments to Mr Di Lellio using the amounts set out in that letter.

I enclose copies of these notices and enclosures. Penalty assessments will be issued under separate cover.

Mr Di Lellio has the right of appeal against these decisions. Any appeals must be made within 30 days of the date of the notice and clearly state:

Exactly what the grounds of appeal are, for example “the income from self
employment is overstated”. Each year should be listed separately unless the grounds are identical for all years.

 Any postponement required

 What the correct amount should be together with supporting documents to verify this…

If there is anything you wish to discuss you can call me on the number shown…Alternatively you can e-mail me.”