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The appellant (an accountant) appealed against a TMA 1970, s 19A notice requiring him to produce certain documents in respect of an enquiry into his tax return.
He claimed that HMRC was trying to extract revenge on him for successfully obtaining a closure notice in respect of one his clients at a General Commissioner’s hearing.
The Special Commissioner said that the question was whether the Inspector reasonably needed the documents to determine if the return was correct, or whether he had another improper purpose.
He said that on the evidence, the Inspector’s only purpose in asking for the documents was in connection with the enquiry into the taxpayer’s return.
There was no intention ‘to get back’ at the taxpayer for his victory on behalf of his client at the General Commissions’ hearing.
The taxpayer’s appeal was therefore dismissed.
