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HMRC internal manual

Inheritance Tax Manual

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HM Revenue & Customs
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Land valuation cases: action where an appeal is received

You must treat any appeal (IHTM37013) as urgent at all stages.

File the appeal and any relevant correspondence with the Notice of Determination (NOD) in the red folder.

You should refer to Litigation

  • any appeal, even if it is late
  • any application for consent to a late appeal.

Litigation will advise whether any appeal may be accepted as being within time and whether the grounds of appeal are sufficiently stated.

If the appeal cannot be accepted, Litigation will take the matter up with the taxpayer or agent.

If the appeal is valid, Litigation will consider whether any worthwhile further negotiations between the VOA (IHTM23002) and the taxpayer or agent are likely. If Litigation considers that further negotiations are unlikely to be productive they will explore with the taxpayer or agent how best to progress the appeal.