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24 April 2012
Issue: 4350 / Categories: Tax cases , Inheritance Tax
Hanson (Trustee of the William Hanson 1957 Settlement) (TC1791)

Under a settlement the father held the farmhouse on trust for himself for life with remainder on trust for his son the appellant.

The father and his brother had a half-share each in farmland. In 1978 the father moved out of the farmhouse and into a property next door while his son and his family moved into the farmhouse under a licence.

No rent was paid but the son accounted for all outgoings and maintenance on the property. He also owned some farmland the operation of which he ran from the farmhouse.

The father died in 2002. The open market value of the farmhouse was agreed at £450 000. HMRC decreed it was not agricultural property within the meaning of IHTA 1984 s 115(2).

The son appealed.

The issues before the First-tier Tribunal were whether the deceased...

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