Summary 
 
An application for a tax return partial closure notice was refused as the First-tier Tribunal (FTT) did not consider that HM Revenue and Customs (HMRC) had the power to issue such a notice in respect of domicile where the quantum of tax was unknown. 
 
Background 
 
The deceased (RWL) was born in the USA in 1937 and remained a US citizen until her death on 19 August 2018. She moved to London in January 1973 and married her partner in 1994 (he died in February 2012). RWL had a residence in London from 1973 until her death. 
 
In January 2016, RWL submitted a self-assessment return for the tax year 2014/15 in which she stated that she was resident in the UK and made a claim for the remittance basis as a result of having a domicile outside the UK. HMRC opened an enquiry into that return. 
 
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