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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Hood v Revenue and Customs (INHERITANCE TAX) [2017] UKUT 276 (TCC) (7 July 2017)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2017/276.html
Cite as: [2017] STC 1707, [2017] BTC 525, [2017] STI 1773, [2017] UKUT 276 (TCC)
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Viscount Hood, Executor of the Estate of Lady Diana Hood v Revenue and Customs (INHERITANCE ) [2017] UKUT 276 (TCC) 7 July 2017
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. Appeal against [2016] UKFTT 59 (TC)
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