(1) THE EXECUTORS OF MRS LESLIE VIVIENNE ELBORNE DECEASED (2) THE TRUSTEE OF THE ELBORNE LIFE SETTLEMENT (3) THE TRUSTEES OF THE ELBORNE FAMILY SETTLEMENT v THE COMMISSIONERS FOR HIS MAJESTY바카라 사이트™S REVENUE AND CUSTOMS [2025] UKUT 00059 (TCC)
Upper Tribunal Tax and Chancery decision of Judges Jeanette Zaman and Vimal Tilakapala 17th February 2025
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INHERITANCE TAX 바카라 사이트“ sale of home by deceased to trustees of a trust in which she held an interest in possession, consideration for which was a promissory note 바카라 사이트“ trustees resolved to allow deceased to continue to reside in home 바카라 사이트“ gift of note by deceased to a second trust under which she was precluded from benefitting 바카라 사이트“ deceased died more than seven years after this gift 바카라 사이트“ FTT dismissed appeal holding that in valuing the estate the liability under the note should be abated to nil under s103 FA 1986 바카라 사이트“ Appellants appealed against that conclusion and HMRC cross-appealed on five issues 바카라 사이트“ held 바카라 사이트“ Note issued by the trustees was not a debt incurred by the deceased 바카라 사이트“ appeal allowed, cross-appeal dismissed 바카라 사이트“ decision of the FTT set aside 바카라 사이트“ decision re-made 바카라 사이트“ appeal allowed
(1) THE EXECUTORS OF MRS LESLIE VIVIENNE ELBORNE DECEASED (2) THE TRUSTEE OF THE ELBORNE LIFE SETTLEMENT (3) THE TRUSTEES OF THE ELBORNE FAMILY SETTLEMENT v THE COMMISSIONERS FOR HIS MAJESTY바카라 사이트™S REVENUE AND CUSTOMS [2025] UKUT 00059 (TCC)