HMRCC v Hanson [2013] UKUT 0224 (TCC)

Wills & Trusts Law Reports | July/August 2013 #131

Mr Hanson (the respondent) is the trustee for a trust created in 1957 by his grandfather, which gave his father Joseph Hanson (the deceased) a life interest. The trust consisted of a house in Milton Keynes.

The deceased lived in the house until 1978 and when he moved out the respondent moved in. There was no change in ownership of the property. The Hansons are a farming family and at the time of his father’s death the respondent owned and farmed 128 acres of land nearby, he rented a further 28 acres and farmed an additional 67 acres co-owned by him and the deceased and ran t...

Hanson v HMRC [2012] UKFTT 95 (TC)

Wills & Trusts Law Reports | May 2012 #119

Joseph Nicholas Hanson (the appellant) appealed against a notice of determination dated 3 October 2005 that had determined that a farmhouse occupied by the appellant as his home at 11 The Green, Great Horwood, Milton Keynes (the house) was not agricultural property for the purposes of inheritance tax relief. HMRC’s position was that the required nexus between a farm building and agricultural land was common ownership and common occupation. The appellant submitted that the required nexus was common occupation only. It was further submitted by the appellant that his father, Joseph Ch...

HMRC v Atkinson & anr [2011] UTUK B26 (TCC)

Wills & Trusts Law Reports | March 2012 #117

Mr Atkinson (D) bought his farm in 1957. The farmhouse was occupied by his son and daughter-in-law, and he lived in a separate bungalow on the farm. In 1996, after his son died, D entered into partnership with his daughter-in-law and grandson and the farm was leased to the partnership. There was no separate arrangement for the bungalow. The farming records were kept there and partnership meetings were often held there. In 2002, D fell ill and eventually moved into a care home. His things remained in the bungalow, which he visited from time to time, but he did not live there again. Howeve...