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HMRC internal manual

Inheritance Tax Manual

Procedures for taking penalties on late accounts: formal penalty proceedings

Formal penalty proceedings may be appropriate if a taxpayer

  • refuses to pay a penalty
  • disagrees with our views on what constitutes a claim for reasonable excuse (IHTM36061)
  • does not respond to our request for a penalty (IHTM36041).If any of these situations apply then you should refer the file to your SO manager (in Compliance Group) or the TSS (in PC&S ) who will consult with Litigation about having the penalty formally awarded by the First-tier Tribunal or a court.