000			01712cab a2200265 4500
001			ABS44344
008			090401t1991 xxu||||| |||| 00| 0 eng d
035			_a(Sirsi) u46684
041			_aeng
245			_aBaird`s Executors v Inland Revenue Commissioners
260			_c1991
350			_a0
490			_aEstates Gazette _v(1991) 09 EG 129-135
520			_aLTS/CTT/1988/1 14 June 1990. Considers whether renunciation of an agricultural tenancy is a chargable transfer for capital transfer tax under Finance Act 1975 s20(2) . Tenancy held since 1935 on implied reletting under original lease granted in 1921 to transferor and his father. In 1936 tenant`s interest made over to transferor by his father. In 1959 landlord accepted transferor`s son as joint tenant. In 1977 the transferor renounced tenancy in favour of daughter-in-law and grandson. Valuation by district valuer based on open market value in terms of Finance Act 1975 s38(2) assuming hypothetical sale of tenant`s interest not prevented by prohibition against assignment based on the Inland Revenue Commissioners v Crossman HL decision. LT held that the transferor was entitled to only a one-half share in tenancy as at the day of his renunciation of the lease on 22 December 1977. Determined the value of the relevant half-share in the tenancy to be £69,000 being half the Inland Revenue`s d
650			_aPROPERTY-LANDLORD AND TENANT-TENANCIES-AGRICULTURAL TENANCIES
650			_aBAIRDS EXECUTORS V INLAND REVENUE COMMISSIONERS
650			_aCAPITAL TRANSFER TAX
650			_aHALF SHARE
650			_aSCOTLAND
650			_aTEST CASE
650			_aVALUE
690			_aTAXATION-CASE LAW
942			_n0
948			_c04/03/1997
999			_c29516 _d29516