IHTM32212 - Appeals against a IHTA84/S219A notice: insufficient time to comply with requirements


If the person who received the notice contacts you to ask for more time to comply and you are able to allow to the request you should agree a revised time scale for production of the information. A revised IHTA84/S219A notice should be issued showing the new date by which the information should be received. The original notice is superseded by the revised notice, and should not be pursued.

If you do not consider an extension of the time limit to be appropriate or you are not satisfied with the taxpayer’s explanation you should write to the person (or agent) setting out your reasons - all such letters should be approved by your Grade 7 manager. The request for an extension is to be treated as an appeal and if not agreed should be referred to Litigation to be listed for hearing by the First-tier Tribunal.

We accept that a person may wish to object to a IHTA84/S219A notice on the grounds that he or she has been given insufficient time to comply with it. However, the Tribunal has no power when considering the appeal to specifically give more time.

If the grounds for an appeal against a notice are that more time is needed to comply and you have been unable to agree a revised timetable, you should refer the case to Litigation before you finally turn down a request for more time.