HMRC v Pawson [2013] UKUT 050 (TCC)

Wills & Trusts Law Reports | April 2013 #128

The Commissioners for Her Majesty’s Revenue and Customs (HMRC) appealed from the decision of the Tax Chamber of the First tier Tribunal (FTT) dated 14 December 2011 ([2012] WTLR 665) to allow an appeal against a notice of determination dated 1 October 2008. The respondents were the personal representatives of Nicolette Vivian Pawson (Mrs Pawson). The notice had determined that Mrs Pawson’s 25% interest in a property known as Fairhaven, Thorpeness, Suffolk (Fairhaven) was subject to inheritance tax on a deemed disposal at the date of her death. Fairhaven was a large bungalow o...

Pawson (dec’d) v HMRCC [2012] UKFTT 51 (TC)

Wills & Trusts Law Reports | May 2012 #119

The appellants were the personal representatives of Nicolette Vivian Pawson (Mrs Pawson) and appealed against a notice of determination dated 1 October 2008. The notice had determined that Mrs Pawson’s 25% interest in a property known as Fairhaven, Thorpeness, Suffolk (Fairhaven) was subject to inheritance tax on a deemed disposal at the date of her death. The appellants contended that Fairhaven was entitled to relief as a relevant business property. Fairhaven was a large bungalow overlooking the sea in a holiday area. It had made a profit for each year since 2003, save for 2005/06...