HM Revenue and Customs could not issue further information notices after they had abandoned appeals against previous notices requiring broadly the same information since there was no reason to suspect a loss of tax or evidence of deliberate, knowing conduct.  
 
In 2005/06, the appellants (husband and wife) gifted a house to their son. They retained the surrounding land for continued use in their business but sold it in 2007. 
 
In December 2015, HM Revenue and Customs (HMRC) commenced checking the appellants’ tax positions and sought information about the land and their disposal of it. HMRC subsequently opened an investigation under Code of Practice 9. In February 2017, information notices were issued to the appellants (under FA 2008, Sch 36). The appellants appealed.  
 
In February 2018, HMRC wrote to the appellants stating that they would not be defending the appeal at the