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HMRC internal manual

Enquiry Manual

Working the Enquiry: Closure Applications: Repeated Applications

TMA 70/S28A(4)

Some taxpayers may make several closure applications during the course of an enquiry. How you deal with each application depends on the stage of the enquiry at which it is made. EM1980.

If a further application is made immediately after the tribunal has rejected an earlier one (in effect, a protest against the direction), you should explain the circumstances to the Tribunals Service, and leave it to the tribunal to decide whether they wish to hear the application again.

A taxpayer may make a closure application for either a partial or final closure notice.