Lady Fox's Exors v Commissioners of Inland Revenue

JurisdictionEngland & Wales
Date1994
Year1994
CourtCourt of Appeal (Civil Division)
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54 cases
  • Clarise Properties Ltd v Rachel Emily Rees and Another
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 28 Julio 2017
    ...the context of a hypothetical sale was given by Hoffmann LJ, with whom Waite and Neill LJJ agreed, in Inland Revenue Commissioners v Gray [1994] STC 360, in relation to the statutory hypothetical sale of the property comprised in the deceased taxpayer's estate immediately before her death f......
  • Price v HM Revenue and Customs
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • 7 Octubre 2010
    ... ... v IR CommrsSCD (2003) Sp C 392 had rejected the Inland Revenue's argument that beneficial shares as tenant in ... Mr Ryder referred us to IR Commrs v Gray (Exor of Lady Fox dec'd)TAX [1994] BTC 8034 for support for his ... ...
  • Decision Nº ACQ 48 2013. Upper Tribunal (Lands Chamber), 02-12-2014
    • United Kingdom
    • Upper Tribunal (Lands Chamber)
    • 2 Diciembre 2014
    ...(Harlescott) Ltd v Secretary of State for the Environment [2000] 2 AC 307 Gray (Lady Fox’s Executors) v Commissioners of Inland Revenue [1994] 2 EGLR 185 Myers v Milton Keynes Development Corporation [1974] 1 WLR 696 Ossalinsky v Manchester Corporation (1883)(unreported) Pentrehobyn Trustee......
  • East Lothian Council For Judicial Review Of A Purported Decision Of The District Valuer Dated 13th April 1999. V.
    • United Kingdom
    • Court of Session
    • 14 Marzo 2001
    ...Council in Raja. He also referred to a passage from the Judgment of Hoffman L.J. (as he then was) in Inland Revenue Commissioners v Gray [1994] STC 360, at pages 371g - 372g. The researches of neither counsel, however, led to the discovery of any authority dealing directly with the construc......
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2 firm's commentaries
  • Tax Update- 21 February 2011
    • United Kingdom
    • Mondaq United Kingdom
    • 28 Febrero 2011
    ...that the valuation exercise had to focus on what was received in the hypothetical sale not what was given. IRC v Gray (Lady Fox's Ex) 1994 STC 360 at pages 372-3 was mentioned for the proposition that one must look realistically at the situation as at 31 March 1982. Cash & Carry v Inspe......
  • Comparables That Glitter Are Not All Gold
    • United Kingdom
    • Mondaq UK
    • 26 Junio 2018
    ...reasonable owner (citing Trocette Property Co Ltd v Greater London Council (1974) 28 P & CR and Inland Revenue Commissioners v Gray [1994] STC 360); (4) policy requirements (depending on how they are expressed) may put the onus of proof on the applicant. An Inspector may reject that par......
2 books & journal articles
  • Table of Cases
    • United Kingdom
    • Wildy Simmonds & Hill Planning Law. A Practitioner's Handbook Contents
    • 30 Agosto 2019
    ...Lawyers at Work Ltd) [2016] UKSC 57, [2017] AC 73, [2016] 3 WLR 1422, [2017] 4 All ER 169 156 Inland Revenue Commissioners v Gray [1994] STC 360, [1994] 38 EG 156, [1994] RVR 129, CA 250, 255 Ineos Upstream Ltd v Persons Unknown [2017] EWHC 2945 (Ch) 526, 566 JA Pye (Oxford) Estates Ltd v W......
  • Viability
    • United Kingdom
    • Wildy Simmonds & Hill Planning Law. A Practitioner's Handbook Contents
    • 30 Agosto 2019
    ...Co Ltd v Greater London Council (1974) 28 P & CR 408, 416). Likewise, in the classic statement in Inland Revenue Commissioners v Gray [1994] STC 360 Hoffmann LJ (as he then was) explained that the hypothetical seller is an anonymous but reasonable vendor, who goes about the sale as a pruden......

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