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Tinkler v HMRC

Supreme Court allows HMRC appeal on validity of enquiry notice sent to taxpayer’s old address.

In Tinkler v HMRC [2021] UKSC 39 (30 July) the Supreme Court allowed HMRC’s appeal finding that the taxpayer was prevented under estoppel by convention from denying that a valid enquiry under TMA 1970 s 9A had been opened.

In 2005 HMRC sent a letter opening an enquiry into the taxpayer’s return. The letter was sent to an old address rather...

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