Readers' forum : Taxi residence

My clients run a company together. They own the shares equally and all assets are held in the name of the company. I have been asked to consider the availability of business property relief on the shares for inheritance tax purposes.

The core business is that of a taxi firm which has developed over a number of years and has been very successful. A little while ago a quite valuable property was bought by the company using its surplus cash which it rented out to employees (and their families) of the company as well as others.

There are clearly some trading and investment activities here. My understanding is that Farmer v CIR determines whether the company is wholly or mainly trading. My brief analysis is that the time spent by the employees in the business as well as the profit and turnover largely relate to the taxi services around...