Information requested by HMRC was not ‘reasonably required’ in relation to the tax year under enquiry and the appellants’ application for the First-tier Tribunal to direct HMRC to close the enquiry was granted. 

Summary 

Information requested by HM Revenue and Customs (HMRC) was not ‘reasonably required’ in relation to the tax year under enquiry and the appellants’ application for the First-tier Tribunal (FTT) to direct HMRC to close the enquiry was granted. 

Background 

The first appellant (D) and the second appellant (M) (husband and wife) operated the third appellant (DMP), a partnership property investment business. On 3 May 2019, HMRC opened an in-time enquiry into D’s self-assessment return for the tax year 2017/18. The enquiry was into “the whole of the tax return.” A schedule was attached to the letter requesting