The Commissioners for HM Revenue and Customs v Empaminondas Embiricos [2020] UKUT 0370 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Adam Johnson and Judge Thomas Scott on 6 January 2021
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PROCEDURE – partial closure notice in relation to HMRC enquiry – can a partial closure notice be issued in relation to a taxpayer’s claim to the remittance basis without specifying the amount of tax due – no – appeal allowed