We became involved in the last stage of a company inland revenue tax investigation when an accountant called us in as he could not make any progress with the tax enquiry.
HMRC were claiming that over £60,000 of tax, interest and penalties were due and also that they had clear evidence of an incorrect certificate of full disclosure being signed (a very serious charge).
HMRC were adamant that this was the minimum amount due and stated that they were willing to raise tax assessments as well as interest and penalty determinations and take the matter to tribunal.
We successfully demonstrated that HMRC should have discovered some of these matters in a previous tax enquiry and were successful in arguing that HMRC could not reopen some earlier years (as well as reducing the amounts due for years where assessments could be raised).
The eventual figure which was agreed as payable was just over £14,000 including interest and penalties.