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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Dealing with taxpayer's replies: inconsistency in taking up cases

An agent may challenge you for taking up the question of penalties on the grounds that your colleagues have not investigated penalties in similar circumstances. You should explain that you are following departmental instructions and firmly but politely continue with your enquiries. You should also ask the agent to refer you to the other cases concerned so that our office can look into the matter. If the agent does give you details of the other cases please refer the matter to the Penalty Portfolio Holder.