In particular, the tribunal judge (Judge Barbara Mosedale) pointed to the fact that BDO, sharing the mistaken assumption that the enquiry was validly opened, actively engaged with the enquiry, and that this led HMRC to acting differently to how they would otherwise have acted and in a way detrimental to HMRC’s interests (because, for example, Judge Barbara Mosedale posited, if BDO had not acted in this way, HMRC would likely have re-issued to the notice of enquiry to the… [read post]