Dear Client,

We have recently been notified of telephone conversations, supposedly instigated by HMRC Officers, in which the officer concerned has stated that the trading of a sole trader or partnership alongside a limited company is fraudulent.  It is remarkable that HMRC can say with such certainty that the fact you are registered as a sole trader and have a limited company is wrong.  It is perfectly acceptable to have several different trading statuses running at the same time as long as the reasons and purpose behind each is different (and commercial). It has never been kept a secret by CL&Co and has often been explained to HMRC as to the reason for the set up.  The first case that I came across was in 1999 when a client, previously with Price Waterhouse Coopers (PWC), was trading both as a director of a production company as well as a self-employed film producer.  PWC stated that the individual would need to be PAYE for all his income and should pay the relevant tax.  I disagreed and stated that, in my opinion, the individual should be paid as a PAYE employee for the Company Director work that he did and Sch D for the individual work that he did as a film producer, even though it was through his own Limited Company.  In light of this disagreement, I wrote to HMRC to ask for guidance.  On 20th Aug 1999, I received a response from a senior Inspector of taxes stating that CL&Co´s treatment of this individual was correct and that he could be both, depending on the work that he did.  This formula has been applied to all individual clients at CL&Co where they are both Director of a company and a worker within it as long as the same criteria matched the case taken to HMRC.

Another reason why an individual might well have both a limited company and be self-employed is due to the nature of the business, what previous work was done (prior to incorporation) and what assets are owned and by whom.  Allow me to explain.  Many individuals begin their working freelance life as a sole trader and the incorporation comes later.  As a self-employed individual they often buy assets, build up contacts and a client base as well as a reputation (often described as ‘good will’ in accounting parlance).  When an individual incorporates, if they were to gift or transfer title of these assets and IP to the incorporated body, the individual could and should expect payment for this transfer as these assets are worth something.  Also removing those assets later on could open the individual to double taxation as they would need to pay tax on the return of ownership (disposal).  If a new company does not have the money to buy these assets (both tangible, such as equipment and intangible, such as good will and IP) outright then a licensing or leasing arrangement could be put in place where the owner of the assets allows the limited (a wholly separate entity) to exploit those assets for gain.  This would lead to the Limited Company exploiting these assets such as the client base, using the equipment and such to gain revenue.  At the end of each year a single transfer is made to the owner of those assets in way of payment for their use.  At the same time and if necessary the individual receives recompense for expenses incurred by that individual and used by the company such as a personal car, an office at home and the like.  This treatment is possible as the Sch D registration is wholly different to that of the limited company.  As the two perform separate tasks and operate under separate treatment, I feel that the treatment is perfectly justifiable.

Since 1999 there has been a few occasions when this set up has been questioned by HMRC as part of normal tax enquiries into client´s affairs and not one of those investigations has led to a permanent objection to this treatment being lodged by HMRC, neither has this treatment ever been overturned by them.  The question, therefore, has to be "why now".  If these treatments, previously verified by HMRC on more than one occasion, have now been identified as being fraudulent then presumably there must be a reason.  It is also true that some accountants will disagree with this treatment as was the case in 1999 with one of the then "Big Four".  These two do not, however, necessarily make the actions of CL&Co illegal.  Nor does it mean that these procedures need to be unstitched leading to extra tax.  HMRC has a duty to treat all taxpayers equally and having approved the methodology so often in the past, cannot simply change their stance unless there has been a change in the law.  Furthermore once HMRC have agreed a procedure for a client in one year they cannot change their mind in a future year, again unless there has been a chance in the law.  There has been no such change in the law.

I am unable to discuss the issue with HMRC as my status has been removed by them.  At the same time many clients are being told by HMRC to go and speak to new accountants and to unstitch this methodology.  They are also being told to do this under arbitrary deadlines which have no legal basis.  What a client does following contact from HMRC is a matter for them individually but at least every client should know that when given the opportunity I will continue to defend these procedures as I have done so successfully in the past.  HMRC appear to be making these claims simply to overturn something in our procedures and therefore justify their actions, in this instance, even though previously they have approved them.

I am sorry for this long explanation but it has been felt by this company for a while now, that an explanation should be given as to the reason behind this set up and why it is felt by CL&Co as being far from fraudulent and perfectly and correctly justifiable.

Yours Faithfully

Christopher

Dear Client,

Following a climb down by HMRC in May of this year, when they reversed a previous decision to allow us to have the evidence used to apply for the original warrants, we have now had a chance to closely examine the evidence presented at Leeds Crown Court in great detail.

It has become clear to us that not only was this evidence materially false but we also suspect one individual of manufacturing further evidence and another of failing to verify evidence as required by PACE and of misleading the court under oath.  It is our firm belief that without these actions having been carried out by the two officers it is unlikely that warrants would have been granted.

The accusations are so serious that we have taken our concerns not only to the Independent Complaints Co-ordinator but also to the HMRC Solicitor handling the case as we believe he will be duty bound to investigate the allegations.

To ensure that an unbiased review of the entire conduct of and continuation of the investigation we have asked not only that the two officers concerned be removed from any ongoing involvement but that the entire investigation be handled by another HMRC Criminal Investigation team based in another part of the country.

We will keep you informed as to HMRC´s response to these allegations and our intended course of action once we have received that reply.

Yours Faithfully

Christopher

Dear Client,

I am writing to you to inform you that as of this morning HMRC have written to us saying they intend on removing our agency status for the second time. The notification, e-mailed to our lawyers this morning, is a single page and disappointingly does not address the voluminous submissions that we made to HMRC regarding the accusations made against us, nor does it address the invitation made by them, welcoming suggestions as to alternatives available for dealing with the investigation whilst allowing us to continue to trade.

It is felt by the management of Christopher Lunn and Company that the removal of our trading status is no accident as we are in possession of clear evidence of negligence regarding the Criminal Investigation Department, including but not restricted to misleading Leeds Crown Court in the application for warrants served on 22nd June 2010.  The evidence that we have clearly demonstrates that the particular client enquiries, used as examples of ´prima facie´ fraudulent behaviour and presented to the court as such, had in fact been shown as being correctly submitted and cleared the year before.

An example of the type of accusation we faced was made public in our Judicial Review hearing in February of this year when Counsel for HMRC used the case of an individual having undeclared income of approximately £65,000.  This accusation made its way in to the national press.  This client had not paid tax on this amount as it was a legacy payment from a relative and as a result would be tax free.  This fact, backed up by letters from the clients lawyers showing the legitimacy of our treatment of this case, were presented to HMRC long before the application for the warrant.  This was the same with the other cases shown to Leeds Crown Court in June 2010.   Each had been addressed and evidenced to HMRC, with the last case being accepted by HMRC as having been addressed in Jan 2010.  Under Home Office Guidance notes issued to officers of the Crown, applying for warrants, there is a requirement for all evidence to have been verified by the applicant.  It is clear to us that no such verification took place.  The applicant declared under oath that the evidence was correct when it clearly was not.  This evidence was subsequently used by HMRC in their first unlawful attempt to stop me from trading.  This was signed off by one of the six Commissioners of The Inland Revenue.  I feel he, at least, should have checked the evidence, before making his unlawful decision.  Mr Dave Hartnett (Permanent Secretary for Tax) in his first letter to me requesting submissions, gave as reasons for his letter the fact that I had already seen HMRC´s evidence.  The only evidence I had seen, at that time, was the false evidence taken to Leeds Crown Court.  This would indicate to me, that he is as much at fault for putting his name to false evidence without feeling it necessary to check.

The negligence, however, does not stop there, as further evidence placed before Leeds Crown Court included an accusation that my son owned property, which was rented out, and that he had purposefully failed to declare the rental income.  This, we believe, was clearly done to bolster the application, to show that the Lunn´s were fraudulent in their private life as well as professional capacity.  A quick 45 minute search using Google enabled us to find the real owner of the properties and to obtain an independent witness to confirm that the owner was not my son and was happy to sign a witness statement to that fact.  Again, if we were able to prove the real owner in a matter of less than an hour, why was it not possible for HMRC to have verified the ownership of this property using other databases not within the public domain?

The final grave failing by HMRC at Leeds Crown Court was to make a commitment, under oath, to the Court that there was no intention to close down the company and to cause minimum disruption to its working practices.  It was clearly stated that there would be controls in place to prevent the uplifting of current work.  In reality there were no controls in place and that none were intended.  HMRC uplifted every single document in the office with no regard to its purpose.  We believe this is a case of deliberate misleading of the court, under oath and we will be taking action on this matter.

Over the last few months we have collected a significant amount of evidence to allow us to explain actions and to alleviate concerns at HMRC.  I was looking forward to bolstering those submissions with an opportunity to face questioning, initially last December, then after HMRC postponed that date, this June.  When HMRC postponed my opportunity to explain and put my interview back again until October this year, I was at least encouraged by the invitation to make submissions and to suggest alternatives to a withdrawal of my trading status.  I was especially encouraged as the invitation came from Dave Hartnett personally.  I took Mr Hartnett at his word and submitted my views and my suggestions for alternative ways of dealing with this investigation moving forward.  In his one page letter e-mailed to my lawyers, he does not address any of my explanations but merely states that his decision is ´fair minded and impartial´ without giving any reasons.  With HMRC acting as Judge and Jury, and without having been interviewed, I fail to see how this decision could be considered as impartial.

I am however, extremely encouraged by the current response I have been receiving from clients of Christopher Lunn and Company who I have spoken to and the level of support from my staff.  We are intending on continuing to trade and to assist current clients with the ongoing submission of their tax returns.  We are able to act in most cases, as company secretary, to ensure the online submission of Limited Company returns and where clients are only a sole trader we will assist in the registration and submission of those tax returns as we have always done.  We will be sending to all our clients a separate letter setting out our procedures now in place to continue to act for you.

Especially in the light of the disgraceful behaviour by HMRC´s Criminal Investigation Department, we are of the opinion that this investigation needs to be handled by an impartial, independent tribunal and will be working tirelessly for that to happen.  In the meantime and despite every action by HMRC to close this firm down, we are determined to continue to trade and to represent our clients in the best way we can.

Yours Faithfully

Christopher

I am writing this letter to update you all on the present situation between HMRC and this firm.

As you know, earlier this year HMRC were found to have acted in a manner that was procedurally unfair in relation to their decision to prevent us acting as Agents without our being given the opportunity to make representations first.   HMRC were ordered to pay our legal costs in relation to our challenge of their decision.

At the same time we were also pursuing a further Judicial Review that was mainly focused on whether or not HMRC had acted unlawfully in their decision not to reveal the details of the information presented by HMRC to Leeds Crown Court and the Central Criminal Court prior to the raid on our premises on 22 June, which was used by HMRC to justify their search warrants.

I can now confirm that HMRC have conceded in relation to this further Judicial Review and that they have now provided us with a copy of the information demanded.   In addition, HMRC have agreed to pay our legal costs in relation to the part of our application for Judicial Review that related to the provision of the information.

There are, however, other outstanding legal issues that still need to be dealt with.

First there is the question of our ability to act as Agents.  On 18th March 2011 Dave Hartnett, head of HMRC and another Commissioner wrote to me stating that they were minded to decide that HMRC will cease to deal with Christopher Lunn and Company as a tax agent.  However, in accordance with the judgment of the court in our first Judicial Review I was given 28 days in which to make representations as to why HMRC should continue to deal with the firm as a tax agent.   HMRC suggested in their letter that we might wish to include alternative suggestions in our representations as to how the firm would be able to continue to act as a tax agent and deal with HMRC.  As a result of HMRC´s letter we submitted five files of representations rebutting the allegations by then made by HMRC along with supporting documentary evidence.   We also included in our submissions the suggestion that in any case where there was an enquiry into a client´s tax affairs we could work with another independent firm of accountants to satisfy HMRC that all was well.  I await the reaction of HMRC to our submissions and this proposal.

Meanwhile, at the same time as Dave Hartnett wrote his "minded to decide" letter, Mike Garrahy wrote to you all advising you that HMRC had made a "provisional decision" to prevent us acting as Agents.  I do not believe that this was correct and our lawyers wrote demanding a withdrawal of Mike Garrahy´s letter.  HMRC´s solicitor responded that the phrase was used simply because laypersons were unlikely to easily understand the legal phrase "minded to decide".  I personally do not agree.   However, since then HMRC have issued a further explanation confirming that they have made no such provisional decision at all.

You may also have seen media reports following our first judicial review success relating to six case examples identified in a letter dated 3rd April 2009 sent to us by Paul Kendrew, an HMRC Inspector.  We think HMRC were wrong to make reference to this letter in Court since in December 2010 our Solicitors had written to HMRC advising them that they should not use this letter as the cases referred to therein had, in general, been settled very satisfactorily in the summer of 2009.

We continue to offer HMRC our full co-operation to end this investigation as soon as possible, and we are currently considering what actions we should be taking in relation to the further information supplied to us when HMRC conceded on the second Judicial Review.

Meanwhile we will continue to prepare and file accounts and tax returns and we remain fully available for advice and assistance in the usual way.  In the old adage, it is "Business as Usual".

Yours sincerely

D.C.C. Lunn

I am delighted to be able to tell you that HMRC has conceded on an important element in our next Judicial Review.

The primary issue in this Judicial Review is HMRC´s refusal to supply the documents it put before the Judge when it applied for the search warrants in June last year.  Our legal team filed and served its argument in respect of this Judicial Review on 12th April and HMRC shortly afterwards supplied the documents.  There are other areas where we consider HMRC has acted unreasonably, and we are therefore currently considering the documents supplied by HMRC, and consulting with Counsel to decide how to proceed.

While preparations for our legal challenge are at an advanced stage, HMRC´s decision to reconsider its position and release this to us is very positive news.  Our lawyers need these documents to be able properly to examine the legality of HMRC´s actions against us, and enable us to respond to the ongoing investigation.

While these legal battles are taking up some management time, we are not allowing ourselves to be distracted from providing our full range of services.  It is still the case that no-one at CLAC has been charged with any offence.  We remain confident that we will be able to clear our name and continue our rightful business for which we have built a long-standing and unblemished reputation.

Yours sincerely

The Management Team
Christopher Lunn & Company

Re: HMRC letter, 18th March 2011

We understand that HMRC has yet again written to all our clients about the possibility that it might be ´refusing to deal´ with Christopher Lunn and Company as tax agents in the future.  We consider that at this stage their letter is disingenuous, at best, and highly prejudicial, at worst.  We have written to them demanding that they retract it.

We are astonished that HMRC have written to you again in such terms given the successful outcome of our High Court case against them.  After that case our tax agent status was reinstated.  Please be assured that we are and continue to be able to deal with HMRC on behalf of all of our clients, as tax agents.  

Now that HMRC have finally provided some of the detail underlying their allegations we will be making forceful submissions to HMRC over the next few weeks about why that should not change.

Yours sincerely

The Management Team
Christopher Lunn & Company

I am very pleased to be able to tell you that on Wednesday 16 February, the High Court delivered its judgment on our application for a Judicial Review and found comprehensively for Christopher Lunn and Company.  In particular, the High Court held that HMRC had acted unlawfully in their dealings with us.  We have been awarded costs against HMRC and will be consulting our lawyers about claiming damages.

The High Court decision overturns HMRC´s decision to refuse to deal with us as an agent or representative for any taxpayer.  HMRC have told us that they do not intend to appeal the Judgment.

When HMRC withdrew our tax agent status in November, we wrote to you saying we considered that their conduct in this regard was unlawful.  It is therefore very reassuring to know that the High Court agrees with us.  We at Christopher Lunn and Company are obviously delighted with the High Court´s judgment.

Christopher Lunn and Company will now take urgent steps to ensure that HMRC deals with us again as a tax agent in all respects including, in particular, the resumption of online filing.

One of the outcomes of the High Court hearing was that HMRC disclosed, for the first time, some of the evidence in relation to the action taken against this company, and also against Christopher and Jonathan Lunn personally, over the course of the past nine months.  We are now strenuously working with our legal team to rebut this evidence.

Please be assured that we will continue to defend ourselves robustly while resuming the same excellent service that our many customers have received over the past forty years.  We will press ahead with our separate application for a Judicial Review of HMRC´s refusal to disclose information that they put in front of the judge who granted the search warrants in June 2010.

We are extremely grateful for your continued support and remain confident that we will be able to clear our name.

In the meantime it is, in all respects, a case of business as usual.

Yours sincerely

The Management Team
Christopher Lunn & Company

Since HMRC´s letter to our clients of 17 September 2010 we have continued to engage in dialogue with HMRC with the aim of advancing our clients´ interests.

In our letter to you dated 11th November 2010 we explained that we would be making representations to HMRC to return all paperwork (including archived materials) removed from our premises on 22nd June 2010.

Despite the fact that HMRC assured you in the 17 September letter that all paperwork would be returned to us four weeks ago, there are still gaps in the material that has been returned to us.  HMRC have not yet begun to return the archive material to us.

We have also been consistently arguing that it is unrealistic for clients to be expected to make a disclosure to HMRC in relation to their tax affairs until all paperwork has been returned to us and we have had a chance to review it.

We are pleased to be able to tell you that this morning HMRC recognised the force of our arguments and formally notified our lawyers that they were going to extend the deadline for CL&C clients to make any disclosures that prove to be necessary to 28th February 2011.  We expect that this revised deadline will enable us to review all clients´ papers once they have been returned to us.

HMRC have also confirmed this morning that it does not need to interview anyone from CL&C until probably before Spring 2011.  We are also continuing to pursue our civil action against HMRC in relation to aspects of its warrants.

In the meantime we are carrying on business as usual.  Please do not hesitate to call your usual contact at Christopher Lunn & Company if you have any queries.  If you have not already done so we would urge all clients to complete their 2009/10 paperwork before the usual compliance deadlines.  If you do feel that you would like to make a disclosure to HMRC now (well in advance of the revised 28 February deadline) we will, of course, be happy to assist you in doing so as far as possible.

Yours sincerely

The Management Team
Christopher Lunn & Company

In HMRC s letter to all of our clients on 17 September 2010, HMRC suggest that clients should consider making a disclosure by 30 November 2010 if clients believe that there may be irregularities in relation to their Tax Return.

As you are aware, HMRC seized the originals of all client files from Christopher Lunn & Company's premises on 22 June, 2010.  As at today's date most of the client files for the current tax year have been returned.   However, HMRC have not returned files relating to any previous tax years and in respect of files that have been returned (i.e. current year files) certain books and records physically contained within those files have not been returned.

On this basis it is clear that HMRC have not complied with - and in all probability were never in practice going to be able to comply with - the deadline of 24 October 2010 mentioned in their letter of 17 September 2010 as the date by which this material would be returned.   And a timeframe of five weeks thereafter to review six years of Accounts for a number of clients was always going to be challenging in the extreme.   We are frankly extremely surprised that HMRC proposed such a tight deadline in the first place.

We should reiterate that we have at all times co-operated fully with HMRC and our approach remains very much to continue to do so.  If you do consider that there is an irregularity in relation to your tax affairs, our advice is that you should contact HMRC in advance of 30 November deadline.  HMRC would then open an enquiry into your current year´'s Tax Return and we could assist with the making of appropriate disclosures thereafter.  However we do regard it as being extremely important that a proper review of files be undertaken to make sure that any disclosure made is comprehensive.  And we would need HMRC to have returned all files to us, including any archived files, before this could happen.

In light of the fact that the deadline of 24 October has not now been met by HMRC it is only reasonable that in circumstances where Christopher Lunn & Co has been instructed to review files and (if appropriate) assist clients with disclosures we should be entitled to a reasonable period of time in which to do so, in particular so as to be able to advise our clients of the appropriate course of action in light of each particular set of circumstances.  Accordingly, we have written to HMRC in order to request an extension to the deadline of 30 November 2010 to a date six weeks after the date that all client files (including archive files) have been returned to us.

We should also inform you that we have commenced legal proceedings in the High Court against HMRC in respect of certain aspects of HMRC´s actions with regard to the search warrants which were executed and the seizure of material.

As a valued client of Christopher Lunn & Company we will of course keep you updated as to the progress relating to the return of your files and also as to any extension to the deadline of 30 November 2010.

Yours sincerely

The Management Team
Christopher Lunn & Company

We promised to write to continue to update you about the investigation being conducted by Her Majesty’s Revenue   Customs ("HMRC"). Christopher Lunn & Company is continuing to co-operate and remains confident that this matter will be resolved satisfactorily in the fullness of time.

We believe that a large number of our clients have received a further generic letter from HMRC dated 17th September 2010, in which HMRC has indicated that some clients´ returns may not be correct.  The letter makes it clear that HMRC will be checking tax returns, that some returns may be the subject of enquiries, and it invites you to contact them if you think there are matters which you ought to have disclosed to HMRC at the time when your tax return was submitted.  The letter identifies a number of respects in which a tax return may not be correct. HMRC´s letter is also clear that if such matters arise in your case and you do not make a voluntary disclosure before the 30th November 2010, they reserve the right to use their usual civil or criminal enforcement procedures against you in due course.

In recent years HMRC has encouraged taxpayers to make voluntary disclosures of undisclosed income or gains or other under-declarations of tax, in particular in cases where assets have been held in offshore bank accounts.  Various incentives for taxpayers to make voluntary disclosures have been offered.  For example, one recent project is known as the "Liechtenstein Disclosure Facility" or "LDF" under which disclosures of offshore income can be made.  The offer made to you by HMRC to make a voluntary disclosure, and offering an incentive if disclosure is made by a particular date, is broadly in line with the approach HMRC has been taking to revenue collection at the present time.

As the letter from HMRC states, you should contact us if you would like access to your papers which will be available from 24th October 2010 if not before (we have a significant number of current files available to us already).  It remains our principal concern to assist all of our clients and work in their best interests at all times, so if you have any further queries or questions please do not hesitate to call your usual contact at Christopher Lunn   Company who will be happy to assist you.

Yours sincerely

The Management Team
Christopher Lunn & Company

As you are aware, Christopher Lunn and Company has been visited by Her Majesty’s Revenue & Customs (HMRC) as part of an HMRC investigation.  Whilst we are fully co-operating with HMRC on this matter, the precise grounds for the investigation still remain unclear.  We are aware that HMRC has sent a standard letter to a number of clients of the firm explaining that the investigation is underway.  HMRC has suggested in that letter that they may need to check the Tax Returns of some clients of the firm.  They have promised to contact clients of the firm again by 20th August 2010.

Whilst we appreciate that this HMRC letter has caused a great deal of concern to those clients who received it, we would like to assure all of our clients that we are taking the ongoing HMRC investigation very seriously and continue to work in the best interest of all our clients.

To this end, we have conducted an internal review of a sample of our client files and have found that there are two areas in particular where Tax Returns could have been prepared in a different manner.

Accountancy Fees
The first issue relates to the standard provision we put in a client's tax return for accountancy and bookkeeping fees.  Since it is impossible for an individu  In many cases this amount is correct but in a minority of cases, where the individual has had limited or no help with their books from us or anyone else and only pays a basic sole trader charge to Christopher Lunn and Company, this could lead to an overprovision for the expense. In cases where this has happened, the overclaim might result in having to make a payment to HMRC of a small amount of further tax.

Use of Home as Office
The second issue relates to claims for ´use of home as office´.

Historically, Christopher Lunn and Company would as a general rule only include a charge of up to £520 per annum for a client´s "use of home as office allowance".  This maximum of £520 (£10 per week) tended to be the limit of what was claimed because our experience of negotiations in tax enquiries into our clients was that HMRC Inspectors tended to object to any higher amounts being claimed.

However, according to HMRC´s internal guidance updated in 2008, use of home as office claims can include a proportion of mortgage interest or rent; utilities; council tax; service charges; house insurance; and cleaning; all without affecting your entitlement to a tax free gain on the sale of your main home ("principal private residence relief").

This means that previous claims for use of homes as office have sometimes been lower than they could have been. An analysis of a cross section of our clients has identified that these use of home as office claims could have been significantly higher. Making an amendment to your Tax Returns, or making a claim for repayment of overpaid tax where amending the return is no longer possible, could therefore result in a tax refund to you.

Of course, in making any such amendment, it would be very important to make sure that any potential overclaim for accountancy expenses was also corrected.

HMRC has suggested in their letter of 9th July that they may wish to enquire into the Tax Returns of more of our clients. Whilst there may be issues with relation to your specific Tax Returns, other than the areas we have identified follow our sample review as discussed above, the purpose of this letter is to reassure you that enquiries work both ways. While there is a chance that an enquiry into your tax affairs might result in the conclusion that you owe more tax it is also possible that the ultimate conclusion would be that HMRC owe you a repayment.

Should you have any questions concerning this letter please do not hesitate to call your usual contact at Christopher Lunn & Company who will be happy to deal with any queries that you may have.

Yours sincerely

The Management Team
Christopher Lunn & Company

We wrote to you last month to explain that our offices had been visited by her Majesty´s Revenue & Customs (HMRC) as part of an investigation.  HMRC must (we presume) consider that it has some grounds for this investigation but we still do not know what they are.  No charges have been brought against Christopher Lunn & Company or any member of our Team.

HMRC has subsequently sent out a standard letter to a number of clients of the firm to explain that this investigation is underway and suggesting that it may need to check the Tax Returns of some clients.  They have promised to contact relevant clients again by 20th August 2010.

We do not feel that this is anything that our clients should be concerned about, given that this is an investigation into Christopher Lunn & Company and not our clients.  However as is the case with any such enquiry, HMRC has the right to look at all records held by Christopher Lunn & Company and by the nature of it this may include clients´ files.

We are continuing to offer HMRC all co-operation necessary and we are in the process of recovering from HMRC copies of any materials that are needed to complete your Tax Returns.  HMRC accepts that there may be delays in meeting submission deadlines as a result of its investigation, but rest assured, as long as we have received all relevant documentation from you, NO financial penalties will be incurred as a result of any delays to the normal process of submitting Returns for you.  We continue to work in the best interests of all our clients, including you and will continue to keep you informed of any relevant developments.

Yours sincerely

The Management Team
Christopher Lunn & Company

We are writing to inform you, as a valued client of Christopher Lunn & Company, that on Tuesday 22nd June 2010 our offices were visited by Her Majesty´s Revenue & Customs (HMRC) as part of an investigation, the precise details of which, at present, remain unclear.

Both our Founder Christopher Lunn and his son Jon Lunn, who also works for the company, are assisting HMRC with the investigation.  Although the investigation must obviously take its course we would like to reassure everyone that no formal charges have been brought against the company or any individuals at the present time.

We wanted to let you know the news personally because you are a very important client to us and we wanted to reassure you that whilst the company is co-operating fully with HMRC, we are confident that this matter will be resolved in the fullness of time.

In the meantime, the business that we have built up over the last 40 years of trading will continue to work to support your very best interests.

We trust that we can continue to count on your support moving forward and will obviously continue to keep you informed of any significant developments.

If you have any further queries or questions please do not hesitate to contact your Team.

Yours sincerely

Management Team
Christopher Lunn & Company