Closure notice re Corporation Tax enquiry
This decision by the Commissioner concerns an application for the closure of enquiries into corporation tax returns for the years ending 31 October 2000 and 2001.
The company was late in producing the actual application for closure and only provided it on the day of the Tribunal hearing. None the less the Tribunal agreed to consider the application as it is the Revenue Commissioners who must be able to satisfy the Tribunal that they have reasonable grounds for not issuing a closure notice.
The Revenue contended that the closure request should not be granted as there were other appeals in respect of annual payments and regulation 80 determinations which were outstanding which may result in the corporation tax assessments being amended.
The application for a closure notice was dismissed by the Special Commissioner.