HMRC Out of Time to Raise Further Questions

I am acting in an estate with claims for RNRB and APR. On their IHT calculation HMRC stated, ‘that if you have not heard from us by 25th May 2020, you can assume we have no questions’. I submitted IHT30 application for clearance on or around 25th May. On 11th June 2020, HMRC issued a letter stating that they were going to be carrying out a check of the IHT400 submitted. Subsequently, HMRC has refused the RNRB and APR claims and referred the valuations of property and land to the District Valuer. When I challenged the Compliance Officer that HMRC were out of time to check the IHT400, I was told, that given COVID-19, the time limit was in effect flexible. Has anyone experienced anything similar? Is the 12 week time limit of HMRC to raise questions enforceable?

Wendy Randall
Hillyer McKeown LLP