Mark Buzzoni (Executor of the estate of Lia Kamhi deceased) and Others v The Commissioners for HM Revenue and Customs: [2012] UKUT 360 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Proudman DBE on 19 October 2012.

Read the full decision in Mark Buzzoni (Executor of the estate of Lia Kamhi deceased) and Others v The Commissioners for HM Revenue and Customs.

Whether s. 102(1)(b) of the Finance Act 1986 (gift with reservation) applies to a gift of a reversionary underlease containing covenants from the donee mirroring covenants in the donor’s head lease. Application of Ingram v. IRC. Decision of the First-tier Tribunal upheld: such covenants do constitute a reservation within the section.

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