67. Determinations; right of appeal.

Where it appears to an officer of HM Revenue and Customs1 that the determination is needed of any amount to be brought into account2 as a receipt in calculating the liability to tax of a person ('the first taxpayer'), and the determination may affect the liability to income tax, corporation tax or capital gains tax of other persons, the officer may give notice (a 'provisional notice of determination') to the first taxpayer and the other persons of the determination he proposes to make and of the rights conferred3 on them4. A person to whom a provisional notice of determination