In the case of proceedings which are commenced by HMRC, we have
the right to decide which body of Commissioners should hear them
but we must elect for one which the taxpayer can elect for under
the rules in TMA70/SCH3 (see AH1081). If none of them are in the
United Kingdom the Commissioners for HMRC may give a direction as
to which body of Commissioners should hear the appeal (see AH1120).
Any election made by HMRC must be notified in writing to the
taxpayer.
Alternatively, a mutually acceptable place of hearing may be
agreed with the appellant (see AH1100).
