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13th August 2019 at 1:53 pm
#4733
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There is a potential argument that HMRC’s original enquiry is invalid as it was made into a voluntary return and that any subsequent “protective” discovery assessment by HMRC (assuming it was otherwise in time) would be either stale or otherwise defective per para 30 et seq of this case: http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j11266/TC07306.pdf