This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

Notices given to partners on closure of partnership tax return enquiry were only partly effective

By Mark McLaughlin, June 2020

Notices given to two partners on the closure of a partnership tax return enquiry were effective to amend the self-assessments of the first appellant partner but not the second. 

Summary 

Notices given to two partners (under TMA 1970, s 28B(4)) on the closure of a partnership tax return enquiry were effective to amend the self-assessments of the first appellant partner but not the second. 

Background 

The appellant taxpayers (ZA and IRS) were each members of a limited liability partnership (LLP) in which they invested with the purpose of generating trading losses in the tax year 2004/05 for offset against their other taxable income for that or previous years. As intended, the LLP purportedly made a substantial trading loss in the tax year 2004/05. 

ZA

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

Additional liabilities confirmed in the absence of credible evidence
By Mark McLaughlin, February 2020
Daily Penalties For Late Filing Were Based On Incorrect Start Date
By Mark McLaughlin, November 2018
Discovery Assessments Were Not Validly Made
By Mark McLaughlin, April 2018
Tax Return Errors Were Deliberate For Penalty Purposes
By Mark McLaughlin, December 2017
HMRC’s Decision Not To Suspend Penalty For Careless Tax Return Error Was Flawed
By Mark McLaughlin, October 2016