Personal bank and/or building society records were reasonably required by HM Revenue and Customs for the purpose of checking each appellants’ tax positions. 
 
The appellant directors of the same company each made individual self-assessment tax returns for 2015/16 disclosing identical income from employment and dividends from UK companies. On 23 March 2017, HM Revenue and Customs (HMRC) opened enquiries into both returns. 
 
HMRC subsequently issued information notices (under FA 2008, Sch 36) requiring the appellants to provide: ‘(1) All bank and/or building society books or statements for any account into which any personal income or from which any personal expenditure was paid for the period 6 April 2015 to 5 April 2016; (2) Certificates or statements of any investment accounts held personally such as ISA’s or bonds, showing any interest received and movement of capital from 6 April 2015