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19In its application for the purpose mentioned in paragraph 18(1) Schedule 36 to FA 2008 has effect as if—
(a)any provisions which can have no application for that purpose, or are specifically excluded by paragraph 20, were omitted,
(b)references to “the taxpayer” were references to the relevant person whose position as regards liability for a penalty under paragraph 1 is to be checked, and references to “a taxpayer” were references to a relevant person,
(c)references to a person’s “tax position” are to the relevant person’s position as regards liability for a penalty under paragraph 1,
(d)references to prejudice to the assessment or collection of tax included a reference to prejudice to the investigation of the relevant person’s position as regards liability for a penalty under paragraph 1,
(e)references to information relating to the conduct of a pending appeal relating to tax were references to information relating to the conduct of a pending appeal relating to an assessment of liability for a penalty under paragraph 1.
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