IHTM23226 | Procedure in the VOA: litigation
From HM Revenue & Customs · Inheritance Tax Manual
Appeal reports (IHTM23090) received by us are referred to Litigation, which will provide guidance on how next to proceed. Where all other avenues fail, or are considered inappropriate, a Notice of Determination (IHTM37001) may be issued. In the event that the valuation is still contested, such cases are then prepared for Lands Tribunal or First-tier Tribunal Hearings, as appropriate.