Vigne v HMRC [2017] WTLR 1193

Autumn 2017 #169

The deceased died on 29 May 2012. At the time she was the sole beneficial owner of 30 acres of land (the land) used for carrying out a livery business. The business provided less than ‘part livery’ (ie day-to-day care being shared between the livery operator and horse owner) but more than ‘DIY Livery’ (ie a right to reside in a field plus a stable). For example the business provided worming products for the horses and hay feed during winter months.

The deceased’s personal representatives claimed BPR on the ground that the land was ‘relevant busi...