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KEVIN SLEVIN suggests that some of the problems with HMRC’s internal reviews and the transition to the new Tribunals Service could easily be ironed out
KEY POINTS
- The importance of 1 April 2009.
- Notification of appeal to Tribunals Service but not taxpayer.
- Why can’t HMRC exercise discretion?
- Can HMRC reconsider their approach?
- A suggested letter.
- An unfortunate legislative quirk.
Following my article Mission Impossible? which focused on the recently introduced HMRC internal review process for direct tax cases I have received enquiries from readers asking for guidance in certain transitional situations.
Instances have arisen where although appeals are proceeding to the first-tier tribunal requests for HMRC to carry out an internal review are being rejected by HMRC case workers.
The first question is therefore whether HMRC can lawfully refuse to offer an internal review in a case destined to be heard by the first-tier tribunal.
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