(1) Where -
(a) in the absence of any agreement between a person and a Revenue officer that the person is liable to a penalty under the Acts, or
(b) following the failure by a person to pay a penalty the person has agreed a liability to,
a Revenue officer is of the opinion that the person is liable to a penalty under the Acts, then that officer shall give notice in writing to the person and such notice shall identify -
(i) the provisions of the Acts under which the penalty arises,
(ii) the circumstances in which that person is liable to the penalty, and
(iii) the amount of the penalty to which that person is liable,
and include such other details as the Revenue officer considers necessary.
(2) A Revenue officer may at any time amend an opinion that a person is liable to a penalty under the Acts and shall give due notice of such amended opinion in like manner to the notice referred to in subsection (1).
(3) Where a person to whom a notice issued under subsection (1) or (2) does not, wit
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