IHTM36164 - Dealing with taxpayer's replies: claims that excess monetary deposits prevent a penalty being sought
Excessive deposits might be made with or before delivery of
an account but the taxpayer or agent makes no reference to
additional assets or under valuations when the account is
submitted. If it is subsequently discovered that the account is
incorrect as a result of the taxpayer’s negligence then a
penalty should be sought. The only link between penalties and tax
is to be able to determine the maximum extent of any penalty.
The ‘offence’ arises at the time the account is
submitted and whether or not additional money has been placed on
deposit over and above that calculated as due on the original
account has no bearing on the matter.
