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HMRC internal manual

Inheritance Tax Manual

Interim reports: stalled negotiations

If the taxpayer fails to respond to correspondence from the VOA (IHTM23002), or if the VOA considers that they are deliberately stalling, they will let us know so that we can agree a strategy for taking matters forward. The usual first course in such cases - assuming that it is worthwhile (IHTM23082) to continue - will be to contact the taxpayer by telephone to see if progress can be made. If it becomes necessary to take things further, consider writing first to the personal representatives (IHTM05012). Thereafter, a ‘best of judgement’ NOD (IHTM37001) might be the answer. In the latter circumstances, you should consult your Team leader and Litigation (if you are in Compliance Group), or refer the file to TSS (if you are in PC&S), before taking such action.