Joint accounts

The deceased lived with K. She had no children but her sister M who was married to P had two daughters S and PT. The daughters married and had five children. K wished the grandchildren to benefit on his death.

When he died in 1996 he left his property including two building society accounts to the deceased. Before she died in 2004 she put the building society accounts into the joint names of herself and P with the instructions that on a death the whole account would pass to the survivor.

The deceased left all her property on trust for sale for the benefit of the grandchildren. No inheritance tax was paid on the building society accounts. P closed the accounts and gave the money to the daughters for the benefit of their children.

HMRC issued two notices of determination...