BIM51615 | Builders, property dealers & developers: valuation: contentious appeal
From HM Revenue & Customs · Business Income Manual
Before making arrangements for a contentious appeal hearing before the First-tier Tribunal on a trading income valuation point, a report, accompanied by the file, should be made to Business Profits (Technical).
The report should set out:
the amount of tax at stake as a result of the disputed valuation, and
confirm that the principle of using open market value has been accepted by the taxpayer and that it is only the amount of the valuation which is in dispute.