Frosh and others v Revenue and Customs Commissioners

Stamp duty land tax – Relief. The taxpayers' application to the First-tier Tribunal (Tax Chamber)(the FTT) seeking a direction for the issue of closure notices in respect of enquiries by the Revenue and Customs Commissioners into stamp duty land tax returns made by the taxpayers was dismissed by the FTT. On appeal, the Upper Tribunal (Tax and Chancery Chamber) dismissed the taxpayers' appeal on the ground, among other things, that, in the circumstances, the FTT had been entitled to decide that the absence of the information and documents relating to the taxpayers' own transactions had provided reasonable grounds for the Revenue not to give a closure notice.

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