000			02190cad a22002295a 4500
001			L146259
008			081223e20080407xxk f v 000 0 eng d
035			_a(Sirsi) u146259
041	0		_aeng
245	0	0	_aMcCall and another (PRs of McClean) (deceased) v HMRC _h[electronic resource]
260			_c2008
520			_a[2008] STC (SCD) 752, 7 April 2008. A landmark ruling in Northern Ireland shows that letting land on popular grazing agreements could jeopardise tax relief. The appellant personal representatives of the estate of a farmland owner (M) appealed against the respondent Revenue's decision that the fields owned by M at the time of her death were not relevant business property under the Inheritance Act 1984 S105. M had sub-let land under agistment agreements to local farmers. Upon M's death the local authority zoned the land for development use which greatly increased its value. Revenue determined that although the tending and letting of fields to graziers constituted a business, it was one which consisted wholly or mainly of the holding of an investment and so the land was not a relevant business property for the purposes of the Inheritance Tax Act 1984 S105. Held: appeal dismissed. The letting of the land was the dominant use and was for profit, which made it a common business. Customs and Excise Commissioners v Morrison's Academy Boarding Houses Association applied. The land was used not to make a living on but to make a living from, as such it was used as an investment.
590			_aKA
650	2	4	_aPHILIP NORMAN MCCALL (2) BERNARD JOSEPH ANTHONY KEENAN (AS PERSONAL REPRESENTATIVES OF EILEEN MCCLEAN, DECEASED) v REVENUE & CUSTOMS COMMISSIONERS
650	2	4	_aINHERITANCE TAX ACT 1984 S105
650	2	4	_aCUSTOMS AND EXCISE COMMISSIONERS V MORRISON'S ACADEMY BOARDING HOUSES ASSOCIATION
651		4	_aUnited Kingdom _y
690			_aPROPERTY-PROPERTY APPRAISAL AND VALUATION-INHERITANCE VALUATION
690			_aPROPERTY-PROPERTY TAXATION-PROPERTY TAX ALLOWANCES-CAPITAL ALLOWANCES
856	4	0	_uhttps://www.financeandtaxtribunals.gov.uk/Aspx/view.aspx?id=3862 _zView the item free of charge at www.financeandtaxtribunals.gov.uk...
942			_n0
999			_c81103 _d81103