*Tinkler v Revenue and Customs Commissioners

Income tax – Self-assessment. The appellant taxpayer had authorised his accountant to act as his agent in his tax matters using Form 64-8, which was downloaded from the respondent Revenue and Customs Commissioners (HMRC) website, which had provided a link to information that stated that certain notices had to be issued direct to a taxpayer. The Upper Tribunal (Tax Chamber) had erroneously held that Form 64-8 had given the taxpayer's agent authority to receive a notice under s 9A of the Taxes Management Act 1970. The Court of Appeal, Civil Division, so held, finding that, interpreting Form 64-8 together with the linked HMRC website page, HMRC had been acknowledging that a formal notice of enquiry was a form that had to be sent to the taxpayer instead of the agent.

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