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HMRC internal manual

Inheritance Tax Manual

Taxpayer does not make the expected offer: culpability disputed but taxpayers prepared to make an acceptable offer

If the taxpayer disputes the level of culpability alleged, but is prepared to make an offer equal, or sufficiently close (IHTM36232) to the expected offer, you can suggest that an offer is made by reference to the HMRC allegation and without admitting any default in the letter of offer. If the taxpayer accepts this you must revise the wording (IHTM36337) of the standard letter of offer (IHTM36331).

Occasionally, the taxpayer will pay the amount asked without being prepared to sign any form of offer. In these circumstances you must acknowledge in the following terms

‘Dear XXXXX,

Thank you for your (client’s) letter of (date) which was accompanied by payment of £XXXX.

I am to inform you that payment of that sum is accepted in settlement of the penalties referred to in (my letter of /our earlier correspondence) and arising out of the (omission/undervaluation) of £XXXX.

My enquiries into this aspect are now concluded.