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Chapter IHTM24123

Document Cited authorities 1 Cited in Related
Vincent
Published date20 March 2016
Record NumberIHTM24123
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
Example

In 1970 A purchased Longacre, a farm in Norfolk, which he first farmed by himself and then from 1975 in partnership with his sons.

A died in June 1989. His partnership interest devolved on his sons under the terms of the partnership agreement. Longacre went to his widow for life as part of the residuary estate.

In August 1990, A’s widow became a member of the occupying partnership. In December 1990, she died. She was still a member of the partnership which had farmed Longacre throughout the period since A’s death.

A’s widow is treated for the purposes of IHTA84/S117 (a) as having occupied Longacre for the purposes of agriculture throughout the two year period before her death because

  • from August 1990 when she became a partner she did occupy the property,
  • under S120(1)(a) she is deemed to have occupied Longacre...

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