A client has not submitted Tax Returns since 1997/98. The Inland Revenue have therefore made determinations, penalties and charged interest for each of the years to date.
We are now looking to submit all the outstanding Tax Returns for our client (including 1997/98). As the 6-year cut-off rule would imply that 1998/99 would be the earliest year open for revision, would we still be able to request our 1997/98 submission override determinations/penalties/interest currently in place?
A previous client in the same situation has been told that the determinations, penalties and interest for 1997/98 will stand even though they had confirmed a Tax Return had been received for that year (they informed us that in these situations the returns would not be processed, merely logged as having been received).
Has anyone come across this before or submitted a valid Tax Return in this situation?
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