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HMRC internal manual

Inheritance Tax Manual

Penalties: introduction

The law imposes certain obligations on taxpayers and provides for penalties when these obligations have not been met, or when they have been undertaken negligently or fraudulently.

Much of the enquiry work in this area arises from omissions or undervaluations of property in accounts submitted to this office.

Your job as an investigator in these circumstances is primarily to satisfy yourself that those concerned acted carefully and reasonably in fulfilling their statutory obligations. You should always approach your investigation on the basis that they will have done so as in many instances the facts will show that to be the case. It is only when the evidence does not satisfy you and clearly points to the alternative conclusion that you should seek a penalty.