On closed files solicitors usually write in to
If the case is a tax-paying file
The values have usually been agreed and the information can
be found in the file. A letter answering the query is all that is
required. Anything that looks like it may require exchanges of
correspondence, or lengthy and/or detailed investigation, should be
re-divided to the other appropriate Teams.
If the case is a non-tax-paying file
These values have often not been ascertained/accepted - as
there is no liability to tax, and in these types of cases HMRC is
not statutorily required to negotiate a precise value. Therefore,
HMRC, as a matter of practise does not agree values for any items
of property etc. unless a value is required for the purpose of
calculating a charge to tax.
If an Instrument of Variation has been completed by the
parties and sent into the Office, then if, because of the Deed, a
calculation of a charge to tax is warranted, then and only then
will the appropriate asset value be formally agreed.
Where letters from outside HMRC are received asking whether
or not we have any questions on an Account that has been
delivered
