FA03/SCH10/PARA14 notices do not oblige a person to deliver
documents relating to the conduct of any pending tax appeal by the
purchaser.
Documents protected by FA03/SCH10/PARA14(5) are only those
which are brought into existence as part of the preparation for the
presentation of an appeal and this limitation should not impede the
issue of a notice where, for example, protective further
assessments have been made and are under appeal.