THE COMMISSIONERS FOR HER MAJESTY'S REVENUE & CUSTOMS
This appeal related to an inheritance tax notice of determination dated 22 May 2013 in respect of the estate of Dr Olive Scott (Olive) who died on 4 March 2007. Olive was predeceased by her husband Professor James Scott (James). The appellant, Malcolm Scott (Malcolm), was her surviving son and co-executor. The other executor had been Olive’s son Alistair Scott (Alistair), who died on 7 November 2009. There had been a dispute between Alistair and Malcolm as to the correct inheritance tax position in relation to certain paintings, and this had led to their filing separate IHT400 accounts in respect of Olive’s estate.
Mr William East for the appellant.
Mr Stuart Douglas (HM Revenue and Customs Solicitor’s Office, South West Wing, Bush House, Strand, London WC2B 4RD) for the respondent.