EM1983 | Working the Enquiry: Closure Applications: Following Contact with the Taxpayer
From HM Revenue & Customs · Enquiry Manual
Contacting the taxpayer at any time during the course of the enquiry including
an informal request for further information, either in writing, on the telephone or at a meeting
a request for a meeting
a request to visit premises
may lead to a closure application. In any of these circumstances you should
attempt to convince the taxpayer and agent of your need to continue the enquiry and
ask them to withdraw the closure application in writing.
Where disputes do arise you should consider whether Alternative Dispute Resolution (ADR) may help you and the taxpayer resolve these before the taxpayer applies to a tribunal for a closure notice. See the ADR web pages for guidance about ADR.
But if the application is maintained you must
be prepared to contest it, and
follow the guidance at EM1990 where the tribunal gives a direction.