If you are pursuing tax not in dispute ( IHTM38022) in a case that is still subject to an enquiry ( IHTM29000) any NOD issued to the taxpayer should make it clear that we are seeking to determine the minimum amount payable.
Draft NOD A (
IHTM38295) should be amended to say :-
"The value transferred on that occasion was not less than
£XXX and the amount of the chargeable transfer was not less
than £XXX".
Draft NOD B (
IHTM38296) should be amended to say :-
"The value transferred on that occasion was not less than
£XXX".
Similar amendments should be made to the other draft NODs in
all open enquiry cases where the amount of the chargeable transfer
may increase.
