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Mark Buzzoni and Others v HM Revenue and Customs – FTC/57-59/2011; UTTC 19 Oct 2012

References: [2012] UKUT 360 (TCC) Links: Bailii UTTC Whether s. 102(1)(b) of the Finance Act 1986 (gift with reservation) applies to a gift of a reversionary underlease containing covenants from the donee mirroring covenants in the donor’s head lease. Application of Ingram v. IRC. Decision of the First-tier Tribunal upheld: such covenants do constitute a … Continue reading Mark Buzzoni and Others v HM Revenue and Customs – FTC/57-59/2011; UTTC 19 Oct 2012

Buzzoni and Others v Revenue and Customs, Re The Estate of Lia Kamhi (Deceased)): CA 19 Dec 2013

Moses, Black, Gloster LJJJ [2013] EWCA Civ 1684 Bailii Finance Act 1986 England and Wales Citing: At FTTTx – Buzzoni and Others v Revenue and Customs FTTTx 21-Apr-2011 FTTTx INHERITANCE TAX – grant of future underlease – covenants reserved – whether donor excluded or virtually excluded – appeal dismissed . . Appeal from – Buzzoni … Continue reading Buzzoni and Others v Revenue and Customs, Re The Estate of Lia Kamhi (Deceased)): CA 19 Dec 2013