Upper Tribunal Tax and Chancery Chamber

UT-2023-000051 - [2024] UKUT 00114 (TCC)

Fecha: 26-Mar-2024

Heading

Neutral Citation: [2024] UKUT 00114 (TCC)

Case Number:UT-2023-000051

UPPER TRIBUNAL

(Tax and Chancery Chamber)

Rolls Building

London EC4A 1NL

Income tax- application for closure notices - whether reasonable for HMRC to continue with their enquiries - FTT directed a closure notice under section 28A Taxes Management Act 1970 – HMRC’s appeal dismissed

Heard on: 26 March 2024

Judgment date: 07 May 2024

Before

JUDGE RUPERT JONES

JUDGE GUY BRANNAN

Between

THE COMMISSIONERS OF HIS MAJESTY’S REVENUE AND CUSTOMS

Appellants

and

JONATHAN HITCHINS (1)
JEREMY HITCHINS (2)
THE EXECUTOR OF STEPHEN HITCHINS (3)

Respondents

Representation:

For the Appellants: Sadiya Choudhury KC, counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

For the Respondents: Keith Gordon, counsel, instructed by Crowe LLP

DECISION