Determination under Section 54 TMA 1970
I have a situation.
Client did not submit returns for in repsect of self emploment 1990-2008 so HMRC issued protective assessments, duly appealed. Client was dillatory in getting proof of income so HMRC threatened a Section 54 determination, then issued one. As client was not in correspondence with us no reply was made so HMRC sent a letter saying 30 days up so now considered final. Any late submission will now have to go before the Tribunal.
HMRC say that this is now standard practice due to move to Tribunal system but could not point me to instructions allowing this but will look it up and get back to me within a fortnight.
Has anyone had any experiance of this?
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