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HMRC internal manual

Capital Gains Manual

Chattels: sets of assets: unagreed cases

Where you are unable to reach an agreement on the existence of a set, it may be necessary to have the matter heard by the First-tier Tribunal.

You should issue a notice of closure on the information available to you.  If this is appealed, you should deal with this in the normal way and then refer the papers to Capital Gains Technical Group.

You need not take any action yourself to bring about the listing of the appeal unless requested to do so by the Capital Gains Technical Group.

In suitable cases arrangements may be made to have expert evidence given in support of your arguments.