TMA70/S31(1)(a) grants the right of appeal against a HMRC
amendment during an enquiry to prevent loss of tax (a jeopardy
amendment). An appeal will normally be made on the grounds that the
assessment is incorrect or the actual liability has yet to be
determined.
If an appeal is made against a jeopardy amendment the
appellant may apply under TMA70/S55(1)(a) (i) to postpone payment
of all or part of the tax etc charged.
Appeals against jeopardy amendments are handled in the same
way as other HMRC amendments (AH2105). However, in accordance with
TMA70/S31(2), the appeal cannot be heard or determined by the
Commissioners until you have issued a closure notice for the
enquiry.
