INHERITANCE TAX – deceased granted reversionary sub-lease to sons out of her
head leasehold interest – licence to sub-let given by head landlord to deceased –
sub-lease provided for same covenants, including repairing covenants, as in head
lease – whether property disposed of by way of gift was subject to a reservation
under s 102 FA 1986 – application of second limb of s 102(1)(b) – identification of
donated property – whether benefit ‘trenched upon’ donees’ enjoyment of the
donated property - Buzzoni considered.