Farming family

I act for a farming family. The property comprises a farmhouse farm buildings and land of approximately 160 acres. Father who died in March 1992 had an absolute interest in a half share in the property. In his will he left one half of his interest to his son absolutely.

He granted a life interest in the other half to his daughter with remainder to the children of the son. Mother who died in July 1996 and held the other half share in the property absolutely made the same arrangements for her share.

Son has resided in the property and farmed the land on a sole basis since the death of his mother. There is no tenancy licence or other right for the brother to occupy the property. Sister who is a higher rate taxpayer is not in receipt of any...