A tax return enquiry notice was not received by the taxpayer and was therefore invalid, but an information notice and its requirements were confirmed.   

On 29 January 2021, the appellant’s self-assessment return for 2019/20 was filed with HM Revenue and Customs (HMRC). On 27 January 2022, HMRC sent an enquiry notice informing the appellant they would be conducting a check of that return, which enclosed a schedule of information and documents required by HMRC to carry out the check.  

On 3 March 2022, HMRC emailed the appellant stating that none of the information requested by 28 February 2022 had been received and therefore it was issuing an information notice. The deadline for provision of the information was 3 April 2022. On 1 April 2022, the appellant’s representative wrote to HMRC stating that the enquiry notice was dated 27 January 2022 and, in terms of the legislation, the closing date for receipt was