EP6612 - Underpayments/Overpayments: ESC A19: When was information received from the taxpayer?

It is normally fairly straightforward to decide when information was received from the taxpayer, and when we should have acted on it. Difficulties can arise when we have no trace of a letter or phone call that the taxpayer claims was sent or made. Every such case should be judged on its merits, using whatever evidence is available, and the benefit of any reasonable doubt given to the taxpayer. If you are satisfied that we did not receive the information then of course ESC A19 cannot apply.