HL 10 December 1998. The owner (I) of a house and land conveyed the fee simple of the whole property to her solicitor to hold as her nominee. The following day, at I`s direction, the solicitor granted her two identical leases of different parts of the property for 20 years rent free. On the day following, also at I`s direction, the solicitor conveyed the property, subject to the leases, to trustees to hold on trusts for the benefit of her children and grandchildren. Following I`s death, the Inland Revenue Commissioners issued a notice of determination that her estate included the unencumbered freehold property valued at the date of her death on the basis that it was `property subject to a reservation`. Following a decision for the Commissioners in the CA, the HL allowed the appeal by I`s executors and held that the term `property` in the Finance Act 1986 s102 did not refer to something which had physical existence but to a specific interest.