The Commissioners for HM Revenue and Customs v Andrew Michael Brander (as Executor of the Will of the late fourth Earl of Balfour): [2010] UKUT 300 (TCC)

Upper Tribunal Tax and Chancery decision of Lord Hodge and Judge Oliver QC on 16 August 2010.

Read the full decision in The Commissioners for HM Revenue and Customs v Andrew Michael Brander (as Executor of the Will of the late fourth Earl of Balfour): [2010] UKUT 300 (TCC).

Inheritance tax Exempt transfers and relief Business property relief Replacement property Deceased having liferent interest in family estate Deceased declared to be fee simple proprietor of the estate Deceased entering into partnership with intended successor Whether deceased s interest in partnership, which subsisted immediately before his death, replaced previous business carried on by deceased Whether business excluded from business property relief as consisting mainly of making or holding investments Inheritance Tax 1984, ss 105(1), (3), 107.

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