Definition and extent of liability: nature of a personal representative's liability
The liability of a personal representative (IHTM05012) is a personal one. Its character as a personal liability is not affected by the limitation on the amount of the liability by virtue of IHTA84/S204 (1).
See IRC v Stannard  STC 245, CTT Cases No. 22.
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Although limitations (IHTM30032) may apply, the liability of a personal representative for IHT is not affected by the fact that for example the deceased may
leave two testamentary writings (as in Ld. Advocate v Douglas’s Exors  55 Rep. CIR, one appointing British executors for his British property, and one appointing foreign executors for his foreign property or
leave one testamentary writing (as in Re Manchester (Dowager Duchess), Duncannon (Viscount) v Manchester (Duke)  1 Ch 540, appointing two separate sets of executors.The liability of an executor de son tort was discussed in IRC v Stype Investments (Jersey) Ltd  Ch 456, CTT Cases No. 15.
The Scottish equivalent of executor de son tort is vitious intromitter.