If you learn that a case has been demanded from the General
Commissioners by the taxpayer, report the full facts at once to the
appropriate specialist.
Once this has been done you should ensure that you have as
much material as possible prepared in readiness for the report
which must be made under AH1545 when the draft case is received.
A taxpayer may demand a stated case even when there does not
appear to be any specific technical point in issue. This can
happen, for example, when an estimated Revenue assessment has been
confirmed by the Commissioners in the absence of the taxpayer. In
these circumstances telephone Cross Cutting Policy(London Technical
Unit) (Advice on appeals). They will advise you whether to submit
the papers with a report straight away or only when the Clerk sends
you a copy of the draft case for comments.
When appeals against alternative assessments on the same
taxpayer (see AH0620) are considered by the Commissioners, they
will typically confirm or determine one of the assessments and
discharge the other(s). The taxpayer may indicate that he is
considering an appeal to the High Court against the decision in
respect of the assessment which confers liability on him. In those
circumstances make an IMMEDIATE report to the relevant specialist
so that consideration may be given to protecting HMRC's position as
regards the assessment(s) which have been discharged.
