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HMRC internal manual

Inheritance Tax Manual

Issuing leaflet IHT 13: draft introductory wording for opening an investigation into an omission

The following wording is suggested as a basis for your covering letter when issuingleaflet IHT 13. The words may need to be amended to suit the particular circumstances ofthe case.

‘You have now notified me of an additional asset which was omitted from the account. In the light of that omission I would like to be satisfied that it was not possible to identify the omitted asset from the information available to the personal representative(s) by the time the account was delivered. I will need to reassure myself that the personal representatives(s) acted carefully and reasonably in carrying out his/her statutory obligations to make the fullest enquiries reasonable practicable in the circumstances to ascertain all appropriate property comprised in the estate.

If the available evidence indicates that it was reasonable to expect the additional asset to have been discovered and disclosed then it may be that a penalty could be sought. Simply because that might be a possibility, I am enclosing copies of our IHT 13 leaflet which explains the law and our practice in this area.’