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The taxpayer filed his personal return for 2007/08 in October 2008. HMRC calculated his tax to be £211 927.
In January 2009 the taxpayer’s accountant amended the return to include a claim for employment loss relief under ITA 2007 s 128.
The loss related to the year 2008/09 but the taxpayer wanted use it in 2007/08 to offset the tax assessed.
The Revenue notified him that it planned to open an enquiry under TMA 1970 Sch 1A ‘Claims etc. not included in returns’ into his loss relief claim on the basis it arose from an avoidance scheme.
In June 2009 the department commenced proceedings against the taxpayer in the county court saying the whole amount of tax was due.
The taxpayer claimed the enquiry should be made under
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