Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Enquiry Manual

From
HM Revenue & Customs
Updated
, see all updates

Partnerships: Jeopardy Amendments - Completion Applications and Appeals

TMA70/S28A(4)

You will normally only make a jeopardy amendment in full partnership enquiries, in which case you should already have opened separate Section 9A enquiries into the return of each partner.

You should normally avoid opening Section 9A enquiries on partners solely for the purpose of making a jeopardy amendment. The taxpayer will have grounds to apply to the tribunal for a direction that you should issue a closure notice.

The tribunal will direct you to complete the enquiry unless you can show reasonable grounds for continuing a separate enquiry into non-partnership aspects of the partner’s return. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Although you will normally conclude enquiries into the partnership and its partners at the same time that will not always be the case. You should bear in mind that the hearing of an appeal against a jeopardy amendment made on a partner will be dependent on the date on which you close the Section 9A enquiry EM3867. The enquiry into the partnership is irrelevant for the purposes of determining the time at which any such appeal can be heard.