Ms Tanner died in September 2017. Her estate included a holiday accommodation business which consisted of five self-catering units which were available for letting most of the year. They were clustered along a private cul-de-sac near Ms Tanner’s residence which included an annexe containing a reception area office and a garage used in the business. The business engaged several staff: a full-time manager; and up to eight part-time employees.
The business undertook housekeeping and cleaning services primarily on changeover days.
The taxpayers claimed business property relief (IHTA 1984 s 105) but HMRC refused the claim on the basis that the business provided customers with furnished holiday accommodation and was an investment activity. The taxpayers appealed.
The First-tier Tribunal looked in detail at the operation of the business bearing in mind also the Upper Tribunal’s decision in CRC v Lockyer and another (personal representatives of...
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