I11.331 Proceedings before the First-tier Tribunal—introduction
In the majority of cases, after notice of appeal has been given HMRC and the taxpayer will seek to settle their differences by correspondence and discussion. As a result many appeals, made necessary by virtue of the 30-day time limit in order to keep the position open for negotiations, are settled by agreement before any hearing is necessary. In other cases, the taxpayer may choose to use the review procedure described above. See I11.312A.
If however the taxpayer does not wish to pursue the review procedure or is dissatisfied with the outcome of the internal review, the taxpayer may notify the appeal to the Tribunal for determination.
The appellant may notify the Tribunal:
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