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Information Notice - application by HMRC for information notices relating UK properties - third-party notice addressed to firm of solicitors - consideration of representations - consideration of legal professional privilege - application granted - Schedule 36, Finance Act 2008
             The application submitted on 22 November 2022 by Jordan Jackson, officer of HM Revenue and Customs, was considered in hearing held in private of which notice was only given to, and which was only attended by, representatives of HM Revenue and Customs, and which took place via a video connection with the Tribunal on 6 December 2022. In addition to Mr Jackson's oral submissions, HMRC submitted an electronic bundle of 373 pages.
             HMRC have applied for an information notice ("the third-party notice") to be issued under paragraph 2 of Schedule 36, Finance Act 2008 ("Schedule 36") to the Third Party, which is a firm of solicitors in Northern Ireland.
             Paragraph 3 of Schedule 36 provides as follows:
(1)���� An officer of Revenue and Customs may not give a third party notice without�
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