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HMRC v Lockyer & Robertson (Mrs NV Pawson’s Personal Representatives)

In HMRC v Lockyer & Robertson (Mrs NV Pawson’s Personal Representatives) (Upper Tribunal – 31 January) a woman who died in 2006 had owned a 25% share in a bungalow in Suffolk which had been let as holiday accommodation. HMRC issued a determination charging IHT on her share of the bungalow. Her personal representatives appealed contending that the letting of the bungalow had been a business and that the bungalow had not been an investment. The Upper Tribunal rejected the latter contention and upheld the determination (reversing the FTT decision). Henderson J held that on the evidence the only reasonable conclusion was that the letting had been a business ‘which was mainly that of holding the property as an investment’. There was nothing to distinguish the business ‘from any other actively managed furnished letting business of a holiday property and certainly no...

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