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In October 2009 EG died intestate. His entire estate which had a net value of £514 600 passed to his son K but remained unadministered. In May 2010 K died also intestate.
His estate passed to his son the second respondent R who was three years old. The inheritance tax payable on the combined estates on K’s death was approximately £89 000 but if R were to take EG’s estate directly no inheritance tax would be due.
The estates of EG and K were held on statutory trust for R contingent on his attaining age 18.
R’s mother E the first claimant did not think it appropriate R should be entitled to income and capital as soon as he was 18 years old.
She and MG the second claimant began proceedings ...
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