If your investigations suggest that taxpayers have included
an estimated value without making the sort of enquiries that they
could reasonably have been expected to make or have entered a
nominal value then you may wish to offer the agents the following
advice to help improve compliance on any future cases that they
deal with.
‘Provisional estimates of value are acceptable and may
be allowed by the Inheritance Act 1984 but only if the fullest
enquiries reasonably practicable in the circumstances have first
been made to establish the open market value. We expect personal
representatives to be able to show that they have done so and we
also expect estimates to be reasoned and properly considered.
Nominal values are not acceptable, neither are estimated
values where it is apparent that other enquiries to establish a
value could and should have been made but were not.’
