IHTM36413 | Public funding for penalty hearings: Public funding and s.245 penalties
From HM Revenue & Customs · Inheritance Tax Manual
We do not believe that Public Funding applies to IHTA84/S245 penalties (IHTM36010). But if a taxpayer wishes to argue before the First-tier Tribunal that an IHTA84/S245 penalty is criminal they should be given the leaflet.