"The phrase "he shall not be assessed", as it is used in s 29, means "he shall not be validly assessed"
“Properly construed, s 8 TMA did not impose a requirement that an officer of the Board was identified in the notice as the giver of the notice. Rather, it imposed a substantive requirement that the giving of a notice had to have been under the authority of an officer of HMR C. The requirement was that whoever required the notice to be given, whether identified or not, had the status of an HMRC officer. The statutory scheme did not justify the approach that a s 8 notice had to be given by an identified ‘flesh and blood’ officer. [my italics] 158. In proceedings in which HMRC's position depends upon a section 8 notice having been so given, the burden will be on HMRC to show that such is the case. In relation to the penalty provisions the Upper Tribunal said in Rogers : [50] It follows that, if HMRC fail to provide any evidence at all to the effect that a s 8 notice was served, they will have failed to demonstrate a crucial fact on which their entitlement to a penalty hinges and the FTT will necessarily set aside the penalties charged for alleged failure to comply with that notice. [51] Where HMRC have given some evidence that a s 8 notice was served, it will then be a matter for the FTT to determine whether that evidence is sufficiently strong to discharge HMRC’s burden of proof. The FTT’s assessment of the evidence should take into account the extent to which the taxpayer is disputing receiving a s 8 notice. Evidence to the effect that HMRC’s systems record a s 8 notice as having been sent is, on its own, relatively weak evidence (since it does not itself demonstrate that a s 8 notice was actually sent, and may not itself demonstrate the address to which it was sent). However, the FTT may nevertheless regard such evidence as sufficient if the taxpayer is not disputing having received a notice to file. By contrast, as the Upper Tribunal (Nugee J and Judge Herrington) identified at [56] of Edwards v Revenue and Customs Comrs[2019] UKUT 131 (TCC) ,[2019] STC 1620 if the taxpayer is disputing having received a notice, the Tribunal is unlikely to accept weak evidence consisting only of a record that HMRC’s systems record a s 8 notice as having been sent to an unspecified address. In such a case, the Tribunal may look for further corroborating evidence: for example evidence that a s 8 notice was actually sent to the taxpayer at the correct address or evidence that the taxpayer set about trying to submit a tax return before the deadline, from which it might be inferred that the taxpayer had received a notice requiring him or her to do so. 159. That was in relation to whether or not a section 8 notice had been served, but clearly the same conclusions apply to the issue of whether the notice was in fact given by or under the authority of an officer. In this appeal on HMRC provided a copy of a print out bearing HMRC’s logo which contained inter-alia the following: "tax year: 2015/16 ... return issued date:06/04/2016 ; ... date of receipt:30/12/2006 ..." but contained no record of the involvement of any HMRC officer. 160. Although he casts some doubt on the accuracy of the document Mr Gordon does not say that no notice was received by Mr Norton, but he says that HMRC have not shown that the notice was given "under the authority of an officer of HMRC". This he says HMRC could surely have done by producing a witness statements from an officer who said, for example, "I instructed someone to program the computer so that notices were sent to people like Mr Norton". Without such evidence how was the tribunal to find that the programming was not done on the whim of a contractor who was not an officer, or that the dispatch of the notice was intended, rather than being the result of a software malfunction or mistake made by such a contractor? 161. Mr Vallis argued that the record of the notice must mean that someone in HMRC authorised its issue: HMRC would not allow, he said, the system to record what had not been authorised. He accepted that the record of the date of issue was a bit dodgy since "06/04/" was shown as the date the return was sent for almost all such records, when it was the case that returns were in fact sent out in batches on dates after 6 April, but that did not prevent it from being evidence of authorisation by an officer. He referred me to Paul at [81] where the judge addressed the issue of whether there was evidence to show that notices had been issued by HMRC rather than someone else (or someone else's computer) and said: “This is a difficult point but on balance I reject this argument. I am satisfied on the evidence that the notices were issued “by HMRC”
“( 1) This section applies where- ( a ) a person delivers a purported return (the relevant return) under section 8, 8A or 12AA (the relevant section) for a year of assessment or other period (the relevant period), ( b ) no notice under the relevant section has been given to the person in respect of the relevant period, and ( c ) HMRC treats the relevant return as a return made and delivered in pursuance of such a notice. (2) For the purposes of the Taxes Acts- (a) treat a relevant notice as having been given to the person on the day the relevant return was delivered, and (b) treat the relevant return as having been made and delivered in pursuance of that notice (and, accordingly, treat it as if it were a return under the relevant section). [subsections (3) and (4) define purported notice and relevant notice square] 178. Mr Vallis argues that if Mr Norton's 2015/16 return was not shown to have been made under section 8 because no valid section 8 notice was shown to have been given, then section 12D saves the day: it treats the return as made under section 8 with the result that an enquiry could be opened - and was opened - and any closure notice issued in relation to such an enquiry was valid and effective. 179. Mr Gordon says that whilst in section 12D validates a voluntary return, it does not retrospectively validate a purported enquiry into such a return which was opened before section 87 was enacted (12 February 2019 ). He says that by deeming a section 8 notice to have been served Parliament has from that date allowed enquiries to be opened prospectively into such voluntary returns, but stopped short of turning previous correspondence into a legitimate enquiry/closure notice. Parliament's choice of language - deeming a section 8 notice to have been given rather than deeming the return to have been in response to such a notice indicates that the deeming effect was intended to be limited simply to validating the voluntary return. He points to anomalies which he says the rise if section 12D is construed to have the effect that a previously ineffective purported enquiry is converted into a lawful one. 180. This argument was rejected by the FTT in Allam v HMRC [2020] UK FTT 26 (TC) , which Mr Gordon told me is being appealed to the Upper Tribunal. 181. I agree with the reasoning and conclusions of the FTT in that case and, in the light of the forthcoming appeal to the Upper Tribunal, no purpose would be served by setting them out in detail here. But Mr Gordon made a number of comments on that decision which I should address. 182. The first related to the FTT's conclusions in [53] and 76] of its decision. The FTT, having considered the approach to deeming provisions and the relevance, context and content of Parliamentary material, said at [53] that section 12D: "should apply to treat...returns...made before12 February 2019 which were not made in response to a notice under section 8 TMA as returns made in response to [such a notice] and so as made under section 8 TMA for the purposes of section 9 a TMA." 183. The FTT then [54 to 62] set out its three reasons for that conclusion, namely, that such: was the ordinary and natural meaning of the words, assisted with the purpose of the provision and was a natural consequence of the deeming provision. Finally [63 to 76] it considered three anomalies which the appellant had argued arose on that interpretation. It then concluded at [76] that: "the deeming rule in section 12D should apply to treat [the voluntary returns as] made in response to a relevant notice and so as made under section 8 TMA for the purposes of section 9A TMA. 184. Mr Gordon says that the language of the conclusions in [53] and [76] misses the point: there is a difference between treating a voluntary return made before12 February 2019 as made under section 8 so that after12 February 2019 an enquiry may validly be started, and the wider interpretation of treating such a return as made under section 8 so that an unlawful enquiry made before12 February 2019 is to be treated as valid. The FTT’s conclusions are apposite only to the first interpretation. 185. I do not think that this is a fair reading of the decision. The conclusion that [53] follows a paragraph in which the second wider interpretation is described, and the conclusion at [53] is plainly to my mind intended to affirm that interpretation as may be seen from the reasons which follow. Likewise the conclusion that [76] follows a discussion of anomalies which were said to rise if the wider interpretation were adopted and is plainly meant to affirm that wider interpretation. 186. The second leg of Mr Gordon's attack on the decision in Allam relates to the anomalies or absurdities that he says will arise if the wider interpretation is adopted. The existence of such anomalies or absurdities flowing from the consequences of a deeming provision make an interpretation which extends to those consequences untenable unless it lies within the purpose of the deeming provision. 187. Mr Gordon's first example is of a voluntary tax return submitted on1 January 2009 in respect of which HMRC purported to open a section 9A enquiry on25 January 2009 . That enquiry would have been invalid. The wider interpretation of section 12D would validate that enquiry. And thus the enquiry he says, would be found to be open 10 years after the event. That he says could not have been intended. 188. Mr Gordon contrasts that situation with a voluntary tax return submitted on1 January 2019 in relation to which HMRC purported to open an enquiry on25 January 2019 (before12 February 2019 the day on which section 12D came into force). The enquiry would have been invalid, but from25 January 2019 HMRC would be able lawfully to open an enquiry if they did so before1 January 2020 . There he says no injustice arises. 189. To my mind the situation in the 2009 example is precisely what was intended. In all likelihood, the “purported” enquiry would have continued for perhaps a few years and resulted in a closure notice, perhaps adjusting up, or down, the self-assessed tax. The wider interpretation treats that adjustment as effective confirming what it is likely that all the parties thought at the time. That is not an absurd result. 190. Mr Gordon's second example (which was also considered by the FTT in Allam [65 to 66]) relates to the provision in section 9A which, if the return is late, extends enquiry window to the end of the quarter one year after the return is made. 191. Under this provision a return made pursuant to a valid section 8 notice on31 January 2019 may be subject to an enquiry within 12 months, but one made late, on1 February 2019 , will be subject to enquiry up to30 April 2020 (section 9 (2)(b)). But the effect of section 12D is that a voluntary return is never late (because it is delivered on the same day as the section 8 notice is treated as being delivered). Thus the enquiry window for a voluntary return is always only 12 months long. As a result an enquiry purported to be opened into a voluntary return after the expiry of 12 months (but within the extended period) would be (and will remain) invalid. 192. This result he says cannot have been intended if Parliament had wanted in section 12D to validate enquiries rather than simply returns. He says it also means that "late filers would be treated more favourably than prompt filers". 193. I accept that the legislation has the effect that enquiries opened in the extension of the window are invalid. But opening an enquiry in such a period is dependent on the return being late, and a voluntary return is never made late because no legislative time limit was applicable at the time it was made. That is consistent with the provision in section 12D that the notice under section 8 is deemed to be given on the day the return is received - a recognition that the return was not late. It does not therefore seem to me that either this example points away from a Parliamentary intention to validate section 9A enquiries or gives rise to anomalies favouring "late" filers. 194. I conclude that in applying the deeming of section 12D "for all purposes of the Taxes Acts" the intention and the effect of the provision was to validate enquiries into section 9A voluntary returns that were opened before12 February 2019 and within the window which would have been applicable at the time for a return made in accordance with a section 8 notice. As a result it validates the results of such enquiries. 195. Therefore if section 12D applies the opening of the enquiry into Mr Norton’s 2015/16 return and any consequent closure notice were valid. Does section 12D apply - the transitional provisions in section 87(4). 196. Subsections 87(3) and (4) provide: - “(3) The amendments made by this section are treated as always having been in force. (4) However, those amendments do not apply in relation to a purported return delivered by a person if, before29 October 2018 — (a) the person made an appeal under the Taxes Acts, or a claim for judicial review, and (b) the ground (or one of the grounds) for the making of the appeal or claim was that the purported return was not a return under section 8, 8A or 12AA of TMA 1970 or paragraph 3 of Schedule 18.” 197. HMRC say that Mr Norton cannot rely on section 87(4) because he did not make an appeal against a closure notice before29 October 2018 , and that if there is a document which could be construed as such an appeal it does not meet the conditions in subsection (4). They say the relevant closure notice was issued on29 April 2019 . 198. Mr Gordon says that the closure ntoice was issued on20 March 2013 and an appeal made on30 March 2017 199. In order to address the effect of these provisions and those arguments I must make some further findings of fact. I find that: (1) Mr Norton's 2015/16 return was received by HMRC on30 December 2016 . (2) Mrs Stent said she was opening an enquiry into the return on27 January 2017 . (3) On20 March 2017 Mrs Stent wrote to say that information obtained by Mr Earl "suggested" that the declared benefit was incorrect. She continued: "I have recalculated your client’s tax liability using a revised figure in relation to car benefits and this has resulted in additional tax being due. "In order to protect the position of HM Revenue & Customs, I have raised an assessment for the tax years ended5 April 2013 to 2015 and amended the tax return for the year ended5 April 2016 . [my italics] "I have ... informally suspended collection ...". (4) On30 March 2017 Mr Dewey of J & G wrote to HMRC and said “I wish to lodge an appeal against ... the adjustment for the tax year 2015/16". (5) On5 October 2018 the tribunal received a notice of appeal from Mr Norton in which ground of appeal number 2 was: "2. So far as any closure notice is concerned HMRC are put to strict proof to demonstrate that there was a valid section 9A notice in relation to a return made under section TMA section 8." (6) HMRC's statement of case dated10 January 2019 indicated (at paragraph 24) that HMRC contended that they correctly issued a section 8 notice and are "perplexed by the suggestion that they did not have the right to enquire". (7) On18 February 2019 Mr Dewing e-mailed HMRC and said in the last paragraph of his letter: "furthermore, we have been advised of a new argument which we wish to employ in relation to the 2015/16 year. We wish HMRC to demonstrate the enquiry was validly opened ... [we believe] the tax return was submitted in response to an automated notice ... [and was] voluntary ... we do not consider a section 12D has the effect of retrospectively validating a non-existent enquiry." (8) On29 April 2019 Mrs Stent wrote to Mr Norton saying "I have now completed my check of your self-assessment. This letter is a final closure notice under section 28. “... my decision ... the amount you declared was understated ... I have amended your tax return in line with my decision." (9) On7 May 2019 Mr Norton sent the tribunal a (second) notice of appeal in which ground 1 was: - "HMRC are put to strict proof to demonstrate that the purported closure notice corresponds with a valid section 9A notice which in turn relates to a return made in reply to a notice given by an officer under TMA section 8." 200. In his skeleton argument Mr Gordon says (paragraphs 58(e) to (g)) that as HMRC’s statement of case did not fully address the section 8 ground of appeal, a clarification was sought on18 February 2019 . I take this to refer to (7) above; he says that the point was raised again on22 March 2019 : I could not find this in the bundles; and that in a response of29 March 2019 (at SB/A20) HMRC newly asserted that the 20 March letter was not a closure notice: I did not find this response there in the bundles. I accept, however, that these steps took place. 201. HMRC now assert that the letter of29 April 2019 was the closure notice for the 2015/16 enquiry. They did not originally think so - their statement of case reveals that they, like the taxpayer appeared to, thought that Mrs Stent’s letter of 20 March was the closure notice for the enquiry. 202. The questions which arise from this are: - (i) was Mrs Stent's letter of20 March 2017 a closure notice? If it was then the appeal against it was made on30 March 2017 or5 October 2017 and section 87(4)(a) is satisfied because the appeal was made before29 October 2018 ; and (ii) if it was a closure notice (so that the5 October 2017 notice of appeal was an appeal against it), was there a ground of appeal that "the purported return was not a return under section 8 ... TMA 1970 ... because no relevant notice was given" so that section 87(4)(b) would be satisfied. 203. If the answer to both these questions is "yes" then the effect of section 87(4) is that section 12D TMA is to be ignored. If on the other hand, Mrs Stent’s letter of20 March 2017 was not a closure notice, then her letter of29 April 2019 was one. In that case the appeal, having been made on7 May 2019 , would not satisfy section 87(4)(a) and section 12D will apply. (i) Was the20 March 2017 letter a closure notice? 204. Section 28A TMA provides that an enquiry is completed when an officer informs the taxpayer by a closure notice that she has completed her enquiries. Section 28A(2) provides that the closure notice must “make the amendments of the return required to give effect to [those] conclusions". In Raftopoulou v HMRC the Court of Appeal said that a closure notice was part of a formal procedure and must “(i) state that the officer has completed his inquiries, (ii) state his conclusions, and (iii) amend the claim as the officer concludes to be necessary or state that no amendment is required.” 205. A closure notice triggers the ability of a taxpayer to appeal and starts the clock running for an appeal. If no appeal is made it may trigger an additional tax liability of the taxpayer. It is important that such a notice is recognisable; the formalities of section 28A enable it to be so. 206. I am not persuaded that Mrs Stent’s letter of20 March 2017 satisfies these requirements. I accept that otherwise than by a closure notice (or notice under section 9C, which plainly this was not) an officer cannot amend a self-assessment and that the letter clearly indicates that an amendment is being made. But I do not think that there can be read into her words the necessary formality of saying that her enquiry was at an end and that she had reached her conclusions. In particular her use of the word “suggested” did not indicate a final conclusion. If Mrs Stent thought she was giving a closure notice or was attempting to do such, she failed. 207. Section 114 TMA provides: “(1) An assessment… or other proceedings which purports to be made in pursuance of any provision of the Taxes Acts shall not be quashed or declared to be void or voidable by reason of any want of form, or be affected by reason of any mistake, defect or omission therein if the same is in substance and affect in conformity with, or according to the intent and meaning of the Taxes Acts…|” 208. Mr Gordon says that if the letter of20 March 2017 was wanting in form, section 114 will save the day because the letter purported to be a closure notice. He says that the Court of Appeal in R(oao Archer) v HMRC [218] STC38 made clear that minor deviations from the statutory scheme would not invalidate a closure notice: section 114 imported an objective test which was whether a reader of the letter, equipped with the knowledge of the taxpayer would have concluded that it was intended to be a closure notice. In this case there was: an open enquiry, and a dispute about the taxability of a benefit in kind. The letter, encompassing as it did the section 29 discovery assessments made it clear that Mrs Stent had made up her mind about those issues and, as a consequence, had decided to amend Mr Norton’s self assessment too. To the observer equipped with such knowledge the letter purported to be a closure notice. It was not enough to say that, because the writer did not expressly say that it was a closure notice or that she had completed her enquiries, the letter did not purport, or seem to be a closure notice or convey that to the mind of such an observer. 209. In Archer the question was whether a letter which called itself a closure notice, said that the officer had completed his enquiries, set out briefly his decisions on the disputed matters, explained what to do if the taxpayer disagreed and said that the return was being amended, but did not set out the amount of tax which was due as a result, was a closure notice. The Court of Appeal accepted that the failure to specify the amount of additional tax payable prevented the notice from complying with the relevant provision, but held that section 114 validated the notice. In those circumstances, where Mr Archer had previously been aware of the sums which would be due, and knew as a result of the letter where he stood with HMRC, section 114 applied to validate the notice ([37,38]). 210. Given the concomitant assessments for the other years, I think it is clear that this notice let Mr Archer know where he stood - in the sense that it was clear that HMRC had reached a decision and that an amount of extra tax was payable by refernce to the benefit of the cars. In that sense the letter may have purported to be a closure notice. But section 114 saves the notice only if it was “in substance and effect in conformity with or according to the intent and meaning of the Taxes Acts”