The deceased owned a property, Carnwethers, on the Isles of Scilly, from which she ran self-catering holiday accommodation business, as well as occasional bed-and-breakfast accommodation. There were four self-catering apartments which were well-furnished and provided with numerous additional amenities, and particularly assiduous concierge assistance from the owners. On her death HMRC issued a notice of determination refusing business property relief on any of the value of Carnwethers on the basis that the business consisted mainly of the holding of an investment.
Louise Graham for the appellants. Simon Bracegirdle (HM Revenue & Customs Solicitor’s Office, South West Wing, Bush House, Strand, London WC2B 4RD) for the respondents.