THE COMMISSIONERS FOR HER MAJESTY'S REVENUE & CUSTOMS
On 5 June 1996 Mrs Kamhi purchased a lease (the headlease) of a flat in Knightsbridge, London. On 21 November 1997 Mrs Kamhi granted an underlease (the underlease) to Ovalap Nominees Ltd. The underlease was granted without rent or premium being payable. On the same day Mrs Kamhi created by deed a settlement. The trustee was Legis Trust Ltd and the trust property was the underlease. Ovalap entered into the underlease as bare nomiee for Legis Trust Ltd.
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Mr Simon Taube QC and Miss Georgia Bedworth (10 Old Square, Lincoln’s Inn, London, WC2A 3SU, tel 020 7405 0758, e-mail firstname.lastname@example.org) instructed by Bracher Rawlins LLP (77 Kingsway, London, WC2B 6SR, tel 0207 404 9400, e-mail email@example.com) for the appellant. Mr Matthew Slater (3 Stone Buildings, Lincoln’s Inn, London, WC2A 3XL, tel 020 7242 4937, e-mail firstname.lastname@example.org) instructed by Solicitor for Revenue and Customs (HM Revenue & Customs Solicitor’s Office, South West Wing, Bush House, Strand, London WC2B 4RD) for the respondent.
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