In AL Price (Mrs RHP Price’s Executor) v HMRC (TC00736 – 20 October) a married couple owned a freehold property as tenants in common. The wife (P) died in 1999. By her will she left her share of the property to her children. It was agreed that if the property were to be sold as a whole it would be valued at £1 500 000. HMRC issued a notice of determination charging IHT on this basis. P’s husband (who was also her executor) appealed contending inter alia that the effect of IHTA 1984 s 161(1) was there should be a substantial reduction in the valuation of P’s half share of the property to take account that of the fact that the property could not be sold with vacant possession. The First-Tier Tribunal rejected this contention and dismissed the appeal in principle...
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In AL Price (Mrs RHP Price’s Executor) v HMRC (TC00736 – 20 October) a married couple owned a freehold property as tenants in common. The wife (P) died in 1999. By her will she left her share of the property to her children. It was agreed that if the property were to be sold as a whole it would be valued at £1 500 000. HMRC issued a notice of determination charging IHT on this basis. P’s husband (who was also her executor) appealed contending inter alia that the effect of IHTA 1984 s 161(1) was there should be a substantial reduction in the valuation of P’s half share of the property to take account that of the fact that the property could not be sold with vacant possession. The First-Tier Tribunal rejected this contention and dismissed the appeal in principle...
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