IHTM30032 - Definition and extent of liability: extent of a personal representative's liability
A personal representative (IHTM05012) is liable for the Inheritance Tax attributable to the property within IHTA84/S200 (1) (a) subject to the following limitations:
Free estate and other unsettled property - IHTA84/S204 (1)(a)
The assets (other than IHTA84/S204(1)(b) property below) which they have received as personal representative or might have so received but for their own neglect or default. In the normal case, the liability is limited to the amount realisable on the assets in question.
Land in the United Kingdom which immediately before the death was comprised in a settlement and which devolves upon or vests in the personal representatives - IHTA84/S204 (1)(b)
So much of that property at any time available in their hands for payment of the tax or which might have been so available but for their own neglect or default.
A personal representative may also be liable for tax resulting from the death other than under IHTA84/S200 (1)