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HMRC internal manual

Inheritance Tax Manual

Taxpayer does not make the expected offer: refusal to co- operate

Where there is a total lack of response from the taxpayer or agent, you should request a meeting to discuss the matter. If this request is refused, you should write to the taxpayer concerned, with copies to the agent, setting out your contentions and seeking an offer of the amount you consider appropriate. You should explain that, in the absence of an offer, your instructions require you in such cases to make a careful overall review of the case so that the possibility of formal penalty action can be considered. If you do not hear from them within 30 days, that review will be started.

You should, of course, make it clear that you would prefer a negotiated settlement rather than to proceed formally.

If no response is received within 30 days, you should follow the same procedures as when culpability is disputed (IHTM36233) for reviewing and referring the case for penalty proceedings.