Commentary

A6.801 Contentious hearings

Administration and compliance

A6.801 Contentious hearings

Division A6.8     Appeals and redress

Division A6.8 revised by
LOUISE PINFOLD, BA (Hons), CTA (Fellow)

For updates affecting this Division please see Part A0 Updates

Appeals and redress

A6.801 Contentious hearings

It is not common for disputes in enquiry cases to be referred to the tribunal1. One reason for this may be that in many cases there is sufficient circumstantial or actual evidence against the taxpayer to cast doubt on his statements. There is also generally enough room for compromise, and the additional costs for each side of pursuing an appeal to tribunal are likely to be significant in arriving at the decision whether to negotiate or to pursue the appeal. In addition to this financial pressure, the prospect of making any compromise settlement that may have been suggested in the course of negotiations is automatically lost.

A recurring theme in appeals taken to

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