The Society appealed against an order construing a will. The will had made a gift of the maximum allowed before payment of inheritance tax, and then a gift of a house. The Society argued that the house gift should be deducted before calculation of . .
The parties disputed the effect of a term in the will leaving a share calculated according to the current rate of exemption from Inheritance Tax.
Held: ‘the purpose of clause 3 was to bequeath a legacy of the amount that was the maximum amount . .
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 that accordingly the transfer did not attract exemption. Held: The finding of the Commissioners … Continue reading George and Loochin ( Executors of Stedman, Deceased) v The Commissioners of Inland Revenue: CA 5 Dec 2003
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 could not claim the benefit of the section 104 exemption. It produced a profitable … Continue reading Inland Revenue Commissioners v George and another: ChD 27 Feb 2003
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 investment income. Income from land is generally investment income, and, on … Continue reading Weston v Inland Revenue Commissioners: ChD 29 Nov 2000
