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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Information Powers: Tax Cases: Johnson v Blackpool Commissioners and CIR, 70 TC 1

A Commissioners precept (S.I. 1994 No 1812 reg 10) was served on the Johnsons to produce books, accounts and documents. Mr Johnson replied that the documents would be available at his house at 11.59pm on a specified date. He subsequently refused access to the books etc.

The Commissioners imposed a penalty for failure to comply which was upheld by the Courts. It was held that the books etc had to be made available at a reasonable time and that the conditions set by Mr Johnson were totally unreasonable.