000			01627cab a2200253 4500
001			ABS60057
008			090401t1999 xxu||||| |||| 00| 0 eng d
035			_a(Sirsi) u91003
041			_aeng
245			_aIngram and another v Inland Revenue Commissioners
260			_c1999
350			_a0
490			_aWeekly Law Reports _v[1999] 2 WLR 91-103(7)
520			_aHL 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.
650			_aFINANCE ACT 1986 S102
650			_aFREEHOLD INTEREST
650			_aINGRAM AND ANOTHER V INLAND REVENUE COMMISSIONERS
650			_aINHERITANCE TAX
650			_aLEASES
650			_aRESERVATION OF BENEFIT
690			_aTAXATION-CASE LAW
942			_n0
948			_c01/02/1999
999			_c57742 _d57742