HM Revenue and Customs v Hanson (As Trustee of The William Hanson 1957 Settlement); UTTC 17 May 2013

References: [2013] UKUT 224 (TCC)
Links: Bailii
Coram: Warren J
UTTTC INHERITANCE TAX – deemed transfer on death – deceased’s estate included a farmhouse – whether the farmhouse was agricultural property within section 115(2) Inheritance Tax Act 1984 – nature of the nexus required between a farmhouse and the agricultural land or pasture etc. in the definition – whether such nexus was occupation and ownership or only occupation -held, the nexus is only occupation – Special Commissioner’s decision in Rosser v IRC [2003] STC (SCD) 311 not followed – appeal from Tax Chamber dismissed.