Whenever you contact a taxpayer, or their agent, to clarify
or question the reasons why an asset was omitted, or under-valued
in the original account, that is an enquiry (
IHTM29011). The penalties section (
IHTM36000) of this manual tells you
when you should seek a penalty.
Imposing a penalty for the late delivery of an account (
IHTM29013) does not amount to opening
an enquiry. If you then challenge aspects of the late account you
will need to open an enquiry at that stage.
