IHTM36052 | Procedures for taking penalties on late accounts: formal penalty proceedings
From HM Revenue & Customs · Inheritance Tax Manual
Formal penalty proceedings may be appropriate if a taxpayer
If any of these situations apply then you should refer the file to your SO manager (in Compliance Group) or the TSS (in PC&S ) who will consult with Litigation about having the penalty formally awarded by the First-tier Tribunal or a court.