Settling the enquiry: introduction: when agreement cannot be reached
The sequence at TTOG5115 presumes an agreement between SI and the taxpayer and adviser at each stage. That is what is sought and is what happens in most cases. In other cases disagreement may arise at each or some of the stages. If these disagreements cannot be resolved then we have to use formal mechanisms to have direct and indirect tax, interest and penalties determined. This is described in SIOG8400.
In most cases we do not remain involved in matters once the civil debt has been established, whether by contract offer or determination. Payment is a matter for Debt Management and Banking (DMB).