| 4.64 | In most cases a
contentious issue that arises within an enquiry can be dealt with
through the appeal procedures at the end of the enquiry. But where
both HMRC and the taxpayer want a particular issue determined by
the tribunal before an enquiry is completed, they can refer the
matter together to the tribunal. The matter will be heard and
determined by the tribunal in the same way as an appeal and the
determination is binding on the parties. It will be taken into
account in the enquiry closure notice (see para 4.65). |
