SA Enquiry - opening letter

SA Enquiry - opening letter

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Letter received from the Revenue stating 'I am writing to tell you that I intend enquiring in to this Return' (2003/04). As the letter does not specify that the enquiry is under S.9A TMA 1970 is it still valid or should it be challenged?
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By martinfoley07
05th Sep 2005 20:31

...attachment?...
Did HMRC enclose a separate list of records/queries with the letter?
Is there a reference to S9A TMA 1970 thereon?
If so, not much point in being picky at this point.
If not, you should write for confirmation.

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By User deleted
05th Sep 2005 21:18

ok i'd say
S9A only requires that notice be given and it looks like it has.

There have been plenty of SA cases before the Special Commissioners now and no one has challenged HMRC's standard phrase when opening an enquiry and similarly no Commissioner has raised any objection.

When was the notice issued?

If close to 31 Jan, notice only takes effect when it is received by the t/p which is basically 2 / 4 working days after posting if issued by 1st / 2nd class.

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