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Disputed value

16 April 2010
Issue: 4251 / Categories: Tax cases , Inheritance Tax
Linda Frances Chadwick and another (Hobart’s executors) v CRC, Lands Chamber

The executors of a will disputed HMRC’s valuation of the deceased’s property. Shortly after the will-maker’s death the executors had obtained valuations from two local estate agents both of whom valued the property at £250 000. It was subsequently refurbished and is now used as a holiday home.

More than a year later after the refurbishment the Revenue visited the property and proposed a value of £300 000. The appellants sent the taxman a detailed report in support of their valuation in light of which a department inspector said he would compromise at £275 000.

The taxpayers appealed.

The tribunal judge noted that the deceased had bought the property privately rather than on the open market. Thus the purchase price – £268 450 – did not conform to the definition of market value in

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