In Golding & Middleton (Golding’s Executors) v HMRC (TC01211 – 10 June) an individual (G) began farming in about 1945 on a small farm with 16.29 acres of agricultural land.
He continued to live in the farmhouse until his death in 2007. HMRC accepted that the land qualified for agricultural property relief but issued a notice of determination charging IHT on the house on the basis that it was not ‘of a character appropriate to the property’ for the purposes of IHTA 1984 s 115(2) and thus did not qualify for relief.
G’s executors appealed. The First-tier Tribunal allowed the appeal finding that the condition of the house was ‘such that it would only be acceptable as a farm house’ and observing that ‘a working farm is not expected to be finished...
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In Golding & Middleton (Golding’s Executors) v HMRC (TC01211 – 10 June) an individual (G) began farming in about 1945 on a small farm with 16.29 acres of agricultural land.
He continued to live in the farmhouse until his death in 2007. HMRC accepted that the land qualified for agricultural property relief but issued a notice of determination charging IHT on the house on the basis that it was not ‘of a character appropriate to the property’ for the purposes of IHTA 1984 s 115(2) and thus did not qualify for relief.
G’s executors appealed. The First-tier Tribunal allowed the appeal finding that the condition of the house was ‘such that it would only be acceptable as a farm house’ and observing that ‘a working farm is not expected to be finished...
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