James Kessler QC and Ross Birkbeck (instructed by Moore Stephens, accountants) for the taxpayer.
Return – Self-assessment – Enquiry – Partial closure notice – Taxpayer applying to tribunal for direction requiring HMRC to issue partial closure notice in relation to enquiry into domicile status – HMRC issuing taxpayer information notice requiring taxpayer to provide information in order to calculate tax due – Whether partial closure notice can be issued without stating revised amount of tax due – Whether reasonable grounds for not issuing partial closure notice – Taxes Management Act 1970, s 28A.