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The deceased had inherited grass land from her husband. It had planning permission for development. The personal representatives appealed against a finding that relief was not available as a relevant business property. . .
Appeal by HMRC from a decision giving judgment for the Trustees on a preliminary issue in relation to the liability of the Trustees to pay tax under the 1984 Act 1984 in respect of a transfer by Mr Dance of agricultural land into the hands of the . .
SCIT INHERITANCE TAX -Exempt transfers and relief – Business property – Relevant business property – Shares held by Deceased in two companies – Whether the business carried on by the companies was excluded from . .
The taxpayers appealed against a decision allowing an appeal by the respondents, that shares in a company which owned land from which it ran a residential caravan park, were shares in a business consisting wholly or mainly of making investments, and . .
INHERITANCE TAX – Business Property Relief – s 104 and s 105 of Inheritance Tax Act 1984 – furnished holiday letting business – whether relevant business property – whether business wholly or mainly of making or holding investments – appeal . .
The company ran a residential homes park. The users owned the caravans, but the taxpayer owned the land. They claimed exemption on a transfer of shares under section 104(1).
Held: The company was an investment company with section 105, and so . .
The taxpayer owned land upon which he ran a caravan park. Income was generated by pitch fees, and from commissions taken from the sales of caravans from one pitch owner to the next. The Commissioners asserted that the income was to be treated as . .
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