EXECUTORS OF THE ESTATE OF MARJORIE ROSS (DECEASED)V
THE COMMISSIONERS FOR HER MAJESTY’S REVENUE & CUSTOMS
Mrs Ross originally owned a hotel called the Port Gaverne Inn in Cornwall and later acquired eight holiday cottages across the road called the Green Door Cottages. When she was no longer fit enough to run the business, the hotel was sold though its new owner agreed to provide services to guests renting out the cottages. A handyman was employed by the partnership which owned the cottages and other properties. When Mrs Ross died on 7 November 2011, she was entitled to a two-thirds share in the partnership and the total value of all the properties held by it amounted to £1.5m. The appellants claimed business property relief from inheritance tax on the value of Mrs Ross’ share in the partnership. On 27 October 2015 a determination was issued by HMRC that the property comprised in the partnership did not qualify for business property relief because it was property of a business which consisted mainly of making or holding investments. The appellants requested a statutory review, which confirmed the determination issued by HMRC. The appellants appealed.