Lloyds TSB Private Banking Plc (personal representative of Rosemary Antrobus deceased) v Peter Twiddy (Inland Revenue Capital Taxes)
Publication details: 2005Subject(s): Online resources: Summary: [2005] EWLands DET 47 2004, 10 October 2005. Concerns the agricultural value of a farmhouse which was held at an earlier hearing to qualify for agricultural property relief as being of a character appropriate to the property. Appeal against the determination of the Special Commissioners ([2002] STC (SCD) 468, unreported) that part of the property, consisting of a dwelling-house and other land had a market value in excess of its value as agricultural property with the consequence that inheritance tax would be payable on the amount by which the market value exceeded the agricultural value. L contended that the agricultural value was the same as the market value. "Held": the value determined by the Inland Revenue to the effect that the agricultural value of the farmhouse was 70% of the market value was correct. Even if the possible bid of a so-called lifestyle farmer purchaser could have been taken into account, a 15% discount from the market value would have to be made in arriving at the agricultural value on account of the effect of the Inheritance Tax 1984 s115(3) covenant.| Item type | Current library | Call number | Copy number | Status | Barcode | |
|---|---|---|---|---|---|---|
| Law report | Virtual Online | ONLINE PUBLICATION (Browse shelf(Opens below)) | 1 | Available | 131626-2001 |
[2005] EWLands DET 47 2004, 10 October 2005. Concerns the agricultural value of a farmhouse which was held at an earlier hearing to qualify for agricultural property relief as being of a character appropriate to the property. Appeal against the determination of the Special Commissioners ([2002] STC (SCD) 468, unreported) that part of the property, consisting of a dwelling-house and other land had a market value in excess of its value as agricultural property with the consequence that inheritance tax would be payable on the amount by which the market value exceeded the agricultural value. L contended that the agricultural value was the same as the market value. "Held": the value determined by the Inland Revenue to the effect that the agricultural value of the farmhouse was 70% of the market value was correct. Even if the possible bid of a so-called lifestyle farmer purchaser could have been taken into account, a 15% discount from the market value would have to be made in arriving at the agricultural value on account of the effect of the Inheritance Tax 1984 s115(3) covenant.