Butler & ors v Commissioners for HMRC [2024] WTLR 23
Wills & Trusts Law Reports | Spring 2024 #194The deceased died on 15 May 2015. At her death she was a member of Tufton Warren Farm LLP. The other member was the trustees of her late husband’s will trust in which she had a life interest, which was treated as part of her estate for IHT purposes under s49(1) Inheritance Tax Act 1984. The LLP owned and ran a wedding venue location. Business property relief was claimed. HMRC issued notices of determination which stated no part of the LLP’s assets was relevant business property for the purposes of s104 Inheritance Tax Act 1984. A statutory review of the determinations l...
Pawson (dec’d) v HMRCC [2012] UKFTT 51 (TC)
Wills & Trusts Law Reports | May 2012 #119The appellants were the personal representatives of Nicolette Vivian Pawson (Mrs Pawson) and appealed against a notice of determination dated 1 October 2008. The notice had determined that Mrs Pawson’s 25% interest in a property known as Fairhaven, Thorpeness, Suffolk (Fairhaven) was subject to inheritance tax on a deemed disposal at the date of her death. The appellants contended that Fairhaven was entitled to relief as a relevant business property. Fairhaven was a large bungalow overlooking the sea in a holiday area. It had made a profit for each year since 2003, save for 2005/06...