Information and documents requested by HMRC in an information notice were reasonably required to check the taxpayers’ tax positions, and the HMRC officer had reason to suspect that an amount which ought to have been assessed to tax had not been so assessed.

The appellants owned a transport company. On 17 October 2019, HM Revenue and Customs (HMRC) opened enquiries into the self-assessment returns of the appellants for the tax year 2017/18, which included a request for information and documents. Having received no response, HMRC issued information notices on 20 November 2019. The appellants appealed.