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 balance, the income from pitch fees was the real business rather than the more occasional commissions, and that, accordingly, the income was investment income, and the business was in ‘making or holding investments’.
Held: The taxpayer was not entitled to relief on the basis that it was a business.
References: Times 29-Nov-2000, Gazette 11-Jan-2001
Judges: Lawrance Collins J
Statutes: Inheritance Tax Act 1984
This case is cited by:
- Cited – Inland Revenue Commissioners v George and another ChD 27-Feb-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 . .
(Times 18-Mar-03, Gazette 01-May-03,  STC 468)
- Cited – Wright and Another v Gater and Others ChD 7-Nov-2011
The beneficiary, a child was to inherit estates of his grandparents and parents, all of which were intestate. An application was made to vary the provisions in order to reduce the liability to Inheritance Tax.
Held: A deferment of vesting . .
(,  EWHC 2881 (Ch), 14 ITELR 603,  1 WLR 802,  STC 255,  STI 3431,  WTLR 549)
These lists may be incomplete.
Last Update: 21 November 2020; Ref: scu.90431