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HMRC internal manual

Inheritance Tax Manual

Calculating the penalty: normal penalty loadings impracticable

Where you have doubts on whether culpability and the penalty position can besatisfactorily established, or if factors such as the incapacity of the taxpayer, throughold age or infirmity, seem likely to prevent a normal negotiated settlement, you shoulddiscuss the case with your manager. You may need to ask for evidence, for example, aletter from a doctor or other medical practitioner before you can accept a plea formitigation.

In some cases it may be appropriate to waive the penalty or seek a nominal amount only,although if there is more than one personal representative and one or more are notincapacitated, this would not normally apply.

If doubts remain the case should be referred to the Penalty Portfolio Holder who willconsider whether advice should be sought from Tax Administration Advice (TAA) (IHTM36361).