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IHTM37080 | Non - Land valuation cases: contentious issue cases

From HM Revenue & Customs · Inheritance Tax Manual

Where negotiations have stalled because of a contentious issue or disagreement over the interpretation of the law, rather than a valuation, HMRC will consider issuing a Notice of Determination (NOD) to resolve the dispute

Taking the Litigation and Settlement Strategy into account, HMRC will consider whether

  • sufficient is at stake in principle or tax or both to justify a NOD and any subsequent appeal hearing

  • there is any prospect of persuading the taxpayer to accept HMRC’s position or of achieving an early practical reconciliation; and

  • a NOD would not prejudice investigations taking place in any other case, or elsewhere in HMRC.

If a NOD is to be issued, it will be a Point of Principle NOD. These types of NOD are drafted according to the particular case. You can find examples of these at (IHTM37094) and (IHTM37095).