SDLTM81940 - Compliance: Working an enquiry

Jeopardy amendments: Appeals

Under FA03/SCH10/PARA35 the purchaser may appeal within 30 days against the amendment and may make a postponement application in the normal way. The appeal cannot be heard and determined until the notice of closure has been issued. But although the appeal itself cannot be referred to a Tax Tribunal, the compliance caseworker should seek to agree the postponement application.

If agreement cannot be reached the postponement application should be referred to a Tax Tribunal for determination.

Where a jeopardy amendment is under appeal, the compliance caseworker may have agreed the amount of tax to be postponed, or a Tax Tribunal may have determined the amount.

If it is subsequently considered, in the light of information obtained since the date of the agreement or determination that the tax postponed was excessive, an attempt to agree with the purchaser a revised figure of tax payable should be made, or refer the application back to the Tax Tribunal.