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Factual background
Factual background
The FTT outlined the lengthy history of the enquiries into the Respondents’ returns at [6], [10]-[45]. Those findings are summarised below.
The Respondents are three brothers, Jonathan, Jeremy and the late Stephen Hitchins (referred to below, respectively, as Jeremy, Jonathan and Stephen and collectively as “the Respondents”).
The Respondents applied to the FTT under section 28A TMA for closure notices in respect of open enquiries into their self-assessment tax returns for the following years:
Jeremy Hitchins
Tax year | Enquiry Opened | Date of Application |
2017/18 | 14 October 2019 | 24 July 2020 |
2018/19 | 20 October 2020 | 28 October 2020 |
2019/20 | 2 December 2021 | 11 February 2022 |
Jonathan Hitchins
Tax year | Enquiry Opened | Date of Application |
2017/18 | 14 October 2019 | 24 July 2020 |
2018/19 | 20 October 2020 | 28 October 2020 |
2019/20 | 2 December 2021 | 11 February 2022 |
- Heading
- Introduction
- Legislation
- Applicable case-law
- Factual background
- Stephen Hitchins (deceased)
- The FTT’s Decision
- Ground 1
- Ground 2
- Ground 3
- Submissions and discussion
- Ground 1 - submissions
- The Respondents’ submissions
- Ground 1 -Discussion
- Ground 2 – submissions
- The Respondents’ submissions
- Ground 2 – Discussion
- Ground 3 – submissions
- The Respondents’ submissions
- Ground 3 – discussion
- Conclusions