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 on 19 October 2012.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 1 December 2016

• Category: Tax
• Release date: 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.

Published 1 December 2016