|
Decision Number: |
TC 04858 |
|
Appellant:
|
Viscount Hood Executor of the Estate of Lady Diana Hood |
|
Respondent:
|
The Commissioners For Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Roger BERNER
|
|
Date Of Decision:
|
02/02/2016 |
|
Main Category:
|
INHERITANCE TAX |
|
Main Subcategory:
|
Gifts |
|
Notes:
|
INHERITANCE TAX – deceased granted reversionary sub-lease to sons out of her head leasehold interest – licence to sub-let given by head landlord to deceased – sub-lease provided for same covenants, including repairing covenants, as in head lease – whether property disposed of by way of gift was subject to a reservation under s 102 FA 1986 – application of second limb of s 102(1)(b) – identification of donated property – whether benefit “trenched upon” donees’ enjoyment of the donated property - Buzzoni considered |
|
Decision(s) to Download:
|
TC04858.pdf 
|
