It is astounding how few practitioners actually bother to find out the names of the Inspectors (most meetings are now conducted in pairs) who will be attending a meeting with their client. This is particularly important where an Inspector from outside of the local tax office chooses to attend a meeting for whatever reason. It is therefore considered prudent to identify the officers with whom your client will be meeting and from which part of the Inland Revenue they are coming, and what role they will be taking at the meeting. It could well be that the Inland Revenue harbour suspicions of fraud against your client.
If any surprises occur at a meeting such as the revelation by an Inspector of a previously unknown bank account with £500,000 in it, the practitioner should request an immediate break to allow him to speak to his client and possibly take the advice of a specialist.
At any meeting Inspectors will invariably inform the practitioner and the client that they will be taking a note of the meeting which will be sent out for agreement and signature. We are always reluctant to allow our clients to sign notes of meeting as they tend to be subjective and slanted in favour of the Inland Revenue just as the practitioner's would be in favour of the client. We cannot imagine the Inspector agreeing to sign a practitioner's note of meeting. It is, however, usually sufficient to comment on any mistakes or misunderstandings. It is also good practice to watch out for omissions by the Inspector of information which may be favourable to your client's case. Usually such omissions will only be spotted by taking detailed notes of your own and indeed retaining those manuscript notes for later reference.
Taxman Ruses
Beware the "pregnant pause" and forewarn clients of the possibility. It is not uncommon for an Inspector to ask a question and then merely sit back and wait for your client to fill the silence. Clients should be advised against filling such pauses and the accountant should play a role in ensuring that sure such pauses do not persist for too long.
Some Inland Revenue Inspectors also seem to like to adopt the 'Sweeney' persona of 'Jack Regan' and 'George Carter' in their good guy/bad guy methods of interrogation/interview. Other than mentioning the possibility to your client, no further advice is probably required in this respect.
In our experience Inspectors who play "naive" or "dumb" are usually among the sharpest Inspectors who need to be treated with some caution. Practitioners and clients alike should not be lulled into a false sense of security by this outward display of ignorance.
Finally, it is worthy to mention the phenomenon we call the "Columbo Question". This is the point in some meetings, usually toward the end of the meeting, when the client and the practitioner feel they have adequately answered all the Inspectors questions and concerns. Then suddenly out of the blue the Inspector asks the question or makes the statement or produces the bit of paper which says "well what about this". Hopefully, this will not happen to practitioners very often as this can be an uncomfortable moment. Often the best response to the "Columbo Question" is either to request time to consider what the Inspector has said or to request an immediate break in the meeting if something is blatantly and obviously wrong, taking specialist advice where necessary.
Conclusion
There is a military adage which floats the notion that "poor preparation prevents perfect performance". We would advocate not underestimating the importance of meetings and following sensible good practice in order to obtain the best possible result for the client. It is vital for the practitioner to prepare himself and his client if costly mistakes are to be avoided.