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Mrs NV Pawson’s Personal Representatives v HMRC

In Mrs NV Pawson’s Personal Representatives v HMRC (TC01748 – 27 January) a woman had owned a 25% share in a bungalow 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 so that the bungalow qualified for business property relief. The First-tier Tribunal accepted this contention and allowed the appeal.

Why it matters: IHTA 1984 ss 103–114 lay down the provisions regulating business property relief and s 105 defines ‘relevant business property’. The Tribunal upheld the appellants’ contention that the bungalow had been ‘relevant business property’ and qualified for relief.

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