R (on the application of Archer) v Revenue and Customs Commissioners

Income tax – Closure notice. Section 28A(2)(b) of the Taxes and Management Act 1970 required the amendment of the tax return to be made by closure notice itself; not merely by an officer of the Revenue and Customs Commissioners. Consequently, the officer's amendment of the taxpayer's online return could not itself satisfy the words of the subsection with the result that the closure notices did not comply with s 28A(2). However, the Court of Appeal, Civil Division, dismissed the taxpayer's appeal on the basis that, in the circumstances, s 114 of that Act operated to validate those closure notices.

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