HMRC -v- Hanson [2013] UKUT 0224 (TCC)

I’ve been sent a copy of a judgment to read through – hopefully I will be able to decode it into something slightly more reasonable. If anyone wants to join the bookclub experience, it is [2013] UKUT 0224 (TCC) FTC/44/2012.

So far, I have established that, barring an appeal, this is about IHT, APR, the nexus binding the relationship between a “farmhouse” and the land pertaining to that farmhouse being different from that previously understood.

I am working my way round to simplifying the judgment in my head, but I think the nexus of ownership rests less on the taxpayer being the common owner, and more on the basis of the land being used for a common purpose, so moving towards ownership *and* purpose. But it’s deep stuff, and a cursory read is all I can manage at the moment. Very technical academic stuff.


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