88 Tribunal approval of taxpayer notices and third party notices

88  Tribunal approval of taxpayer notices and third party notices

(1)     WRA may apply to the tribunal for approval to issue a taxpayer notice or a third party notice to a person (“the recipient”) without notice of the application being sent to the recipient.

(2)     Where notice of the application for approval is not sent to the recipient, the tribunal may approve the issuing of the taxpayer notice or third party notice only if it is satisfied—

(a)     that—

(i)

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