14(1)Where a person who has stood in relation to others as a tax accountant—U.K.
(a)is convicted of an offence in relation to tax by or before a court in the United Kingdom, or
(b)has a penalty imposed on him under section 96 (assisting in preparation of incorrect return etc),
an authorised officer of the Board may by notice in writing require that person to deliver to him such documents as are in his possession or power and (in the officer’s reasonable opinion) contain information relevant to any tax liability to which any client of his is or has been, or may be or have been, subject, or to the amount of any such liability.
(2)An “authorised officer of the Board” means an officer of the Board authorised for the purposes of this Part of this Schedule.
(3)Before a person is given a notice under this paragraph he must be given a reasonable opportunity to deliver the documents in question.
No application for consent under paragraph 16 shall be made unless he has been given that opportunity.