A partial closure notice in an enquiry by HMRC could not be issued in relation to a taxpayer’s claim to the remittance basis without specifying the amount of tax due.
Summary
A partial closure notice in an enquiry by HM Revenue and Customs (HMRC) could not be issued in relation to a taxpayer’s claim to the remittance basis without specifying the amount of tax due.
Background
The taxpayer (who was originally from
