In Mrs G Silber (MMM Lerner’s Personal Representative) v HMRC (TC02369 – 20 November) an individual (L) died in 1999. He was a shareholder in a company (T) and T’s records showed that L had lent T £107 210. HMRC issued a notice of determination including this £107 210 as part of L’s estate. L’s personal representative appealed contending that the £107 210 should have been treated as a gift to T rather than a loan. The FTT rejected this contention and dismissed the appeal.
Why it matters: The FTT upheld HMRC’s contention that the amount which the deceased had lent to the company formed part of his estate for IHT purposes.
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