John Brassey is a tax director at Lancaster Knox LLP specialising in HMRC enquiries, penalties and powers. He can be contacted on 0203 7575669 or email: johnbrassey@lancasterknox.com.The views expressed are those of the author and not necessarily those of Lancaster Knox LLP. The author, and Lancaster Knox LLP, cannot be held liable for any action, or inaction, based on the contents of this article.