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HMRC v Richard Evans (TC3759)
Constance Sootheran died on 30 October 1976 and left a property to her husband who was appointed executor along with his late wife’s brother Herbert Evans.
Hugh Warwick Evans and the taxpayer were subsequently appointed as trustees with the original executors.
The husband died on 1 January 2010 and the residuary estate passed to Mrs Sootheran’s nephews and nieces. The taxpayer was the sole surviving trustee liable for the inheritance tax (IHT).
HMRC wrote to him times between 13 August 2010 and 6 August 2013 and also tried telephoning but received no response.
The department finally sent the taxpayer a notice of determination which stated the value of the property at the date of Mr Sootheran’s death was at least £65 473 and that IHT of £22 550.28 was due together with interest of £2 332.66.
The Revenue then applied to the First-tier Tribunal to impose...
