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HMRC internal manual

Inheritance Tax Manual

Valuing property in an estate: authority for valuing items of property together

The authority for valuing items of property together if they would fetch more than if sold separately is Att-Gen of Ceylon v Mackie [1952] 2 All ER775.

This was followed by Gray v IRC [1994] STC 360 where the deceased, Lady Fox, owned a 3,000 acre estate which she let to a partnership in which she had a 92.5% share. The Court of Appeal held that for the purposes of IHTA84/S160 the land and the deceased’s interest in the partnership should be valued together as a single unit of property. The value for that single unit was higher than the combined value for the land and partnership interest when valued as separate items of property.