A penalty notice of determination under FA03/SCH14 must be
served on the person liable to the penalty, usually the purchaser.
The notice must also state
The determination is to be considered final unless HM Revenue
& Customs decides it is excessive see
SDLTM86720, or an appeal against the
determination is upheld, see
SDLTM86730.
Where a person who has incurred a penalty has died a
determination under FA03/SCH14/PARA2 which could have been made in
relation to them, may be made in relation to their personal
representatives.
Any penalty imposed on personal representatives by virtue of
this subsection shall be a debt due from and payable out of the
deceased’s estate.