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The appellants who were executors claimed agricultural property relief under IHTA 1984 s 115 in respect of the deceased’s farm. HMRC disallowed the claim on the basis the property was not agricultural property within the meaning of s 115(2).
The deceased’s father had bought the farm for him in 1940. The deceased had modernised the buildings and put up sheds for farm equipment. The farmhouse was integral to the land farmed. As the deceased grew older he cut down on the level of farming to the extent that from the 1990s the farm income was not sufficient to live off.
The issue before the First-tier Tribunal was whether the farmhouse was of an appropriate character to 16.29 acres of agricultural land. The tribunal decided it was.
The tribunal judge said...
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