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The Earl of Balfour inherited on the death of his father a liferent interest in a family estate in 1968.
In 2002 he entered into a limited partnership with his nephew who was his intended successor. The earl died in June 2003.
HMRC denied business property relief in respect of the limited partnership either on the grounds that the interest in the partnership was an investment or that it had not replaced earlier business property so the two year period of ownership test had not been met. The personal representatives appealed.
The tribunal judge said that the estate had always been managed by the deceased as a single business despite operating under two names prior to the partnership.
He took de facto responsibility for the running of the whole estate making business decisions himself.
As a liferenter the Earl had to...
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