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Pitt & Others v HMRC

In Pitt & Others v HMRC (Supreme Court – 9 May) an individual (P) suffered serious head injuries in a road accident in 1990. He was rendered permanently incapable of managing his own affairs and his wife was appointed as his receiver. In 1994 P was awarded substantial damages. On the advice of solicitors P’s wife put these payments into a settlement.

The form of settlement gave rise to significant liability to inheritance tax (under IHTA 1984 s 237). P’s wife did not discover this until 2003. She applied for a declaration that she should be entitled to unravel the settlement and a related assignment. The CA rejected this contention but the Supreme Court unanimously allowed P’s appeal holding that a voluntary disposition could be set aside on the grounds of equity where there had been a mistake which was sufficiently serious to satisfy the conditions...

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