McCall & anr v HMRCC [2009] NICA 12

December 2011 #115

The appellants were the personal representatives of Mrs Eileen McClean (the deceased), who died on 8 January 1999. The appellants claimed that 33 acres of agricultural land in the deceased’s estate, which at the date of the deceased’s death was valued at £5.8m, owing to it having been zoned for development use, was business property for inheritance tax (IHT) purposes. The respondent, HMRC, determined that no part of the value of the agricultural land transferred on death was attributable to the value of any relevant business property.

The land comprised a number of fields in grass...