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 reservation within the section.
Statutes: Finance Act 1986 102(1)(b)
This case cites:

• Appeal from – Buzzoni and Others -v- Revenue & Customs FTTTx (Bailii, [2011] UKFTT 267 (TC))
  FTTTx INHERITANCE TAX – grant of future underlease – covenants reserved – whether donor excluded or virtually excluded – appeal dismissed . .

This case is cited by:

• Appeal from – Buzzoni and Others -v- Revenue & Customs, Re The Estate of Lia Kamhi (Deceased)) CA (Bailii, [2013] EWCA Civ 1684)
  . .