Confused partnership

Mr and Mrs M acquired the freehold interest in Wrag Farm in 1967. Twenty years later they acquired a VAT-registered company Wrag Barn Golf and Country Club Ltd for the purpose of converting part of the farmland into a golf course

One of Mr and Mrs M’s sons T oversaw the development of the course which was completed in June 1990 when Mr M sent various documents to HMRC. They included forms VAT1 and VAT2 to effect registration of the partnership with effect from 27 June 1990 and an option notice in respect of the golf course.

It was confirmed that Mr and Mrs M’s sons had been made partners in the golf club business on 1 July 1990 the same date on which Mr and Mrs M executed a deed of gift by which they conveyed the site of the golf...