The taxpayer’s corrective action form could not be used to make further consequential amendments to his self-assessment return, and the conclusion in an HMRC enquiry closure notice that no amendment was required to the tax return was not appealable. 

The appellant’s tax return for 2007/08 was filed on 19 August 2010. The calculation of income tax due was £0 and the return included (as relevant): (1) ‘other taxable income - before expenses and tax taken off’ (box 15) of £1m; (2) a net loss in self-employment (trading in used cars) of £1,108,228 (box 63); (3) a claim for £1,025,390 of the losses to be set against other income for the same tax year; (4) a claim for £82,838 of the losses to be carried back to previous tax years; and (5) a disclosure that the ‘Working Wheels’ tax avoidance scheme had been used. 

During an HM Revenue and Customs (HMRC) enquiry into the appellant;