000			01365cab a2200265 4500
001			ABS57683
008			090401t1997 xxu||||| |||| 00| 0 eng d
035			_a(Sirsi) u81053
041			_aeng
245			_aIngram and another (Executors of the Estate of Lady Ingram, deceased) v Inland Revenue Commissioners
260			_c1997
350			_a0
490			_aSimon`s Tax Cases _v[1997] STC 1234-1271(18)
520			_aCA 28 July 1997. Involved a gift of the freehold of Lady Ingram`s house conditional on the grant of a lease-back so that L could settle her home on trust for her family while retaining a sufficient interest to allow her to occupy the property for the rest of her life. L died within two years of making the settlement and the IRC issued a notice determining inheritance tax was payable at the death rate. Executors appealed. "Held" nominee could not contract with his principal to create rights in relation to the subject of his nomineeship. The leases to Lady Ingram were a nullity.
650			_aFINANCE ACT 1986 S102
650			_aFREEHOLD INTEREST
650			_aINGRAM AND ANOTHER (EXECUTORS OF THE ESTATE OF LADY INGRAM, DECEASED)
650			_aINHERITANCE TAX
650			_aLEASE-BACK
650			_aLIFETIME TRANSFER
650			_aRESERVATION OF BENEFIT
690			_aTAXATION-CASE LAW
942			_n0
948			_c24/09/1997
999			_c51065 _d51065