Postby wamstax » Mon Mar 12, 2018 11:19 am
On the principle of he who asserts must prove just to provide a statement of account (assumption from your post) tells you nothing.
Unless
(A)you failed to file returns for the relevant years or
(B) failed to pay taxes you had self assessed or
(C) failed to include all your income on the tax returns for the years ended 5th April 2002 or 2003 or
(D) HMRC had made a determination of unpaid duties in absence of returns
there is no way that there could be these “under payments” in the absence of an enquiry into these tax returns following a notice under S9 TMA 1970.
In 2007 they could have raised an assessment for 2003-04 under the normal S29 [Discovery provisions] if they discovered ( only after the time limit for enquiring into each tax return had elapsed) that income had been under assessed irrespective whether you were negligent. However for the earlier years HMRC would require to prove that you were at least negligent in each of these two years before being able to validate their assessments and if they can’t then they now need to prove matters.
While they say there are no grounds for appeal there is one as follows “ I did not receive any enquiry notice; closure notice - which would in any case be invalid as I did not receive an enquiry notice; or assessment - which would in any case be invalid as there has been no discovery that income was understated nor have you proved that I was negligent in the submission of my returns. Nor am I aware that I did not file the correct returns for these years or pay any taxes self assessed by me”
regards and hope this helps
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