IHT dispute concerning dividing estate residue:In S Changizi v P Changizi and another [2025] EWHC 735 (Ch) (2 April) is a dispute between mother and son as to how the burden of the IHT liability should be met. In this case the English estate of a testator was left (after a deed of variation) as to 5/6 to his surviving spouse and 1/6 to his son. The executors had also paid IHT on failed potentially exempt transfers (PETs) to the son for which they had a secondary liability. There had already been considerable litigation in this case and considerable costs had been run up which had been awarded against the son. After the costs and IHT paid on the failed PETs the son was in debt to the estate before any distribution was made.
The son claimed that the IHT due on the estate should be deducted...
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IHT dispute concerning dividing estate residue:In S Changizi v P Changizi and another [2025] EWHC 735 (Ch) (2 April) is a dispute between mother and son as to how the burden of the IHT liability should be met. In this case the English estate of a testator was left (after a deed of variation) as to 5/6 to his surviving spouse and 1/6 to his son. The executors had also paid IHT on failed potentially exempt transfers (PETs) to the son for which they had a secondary liability. There had already been considerable litigation in this case and considerable costs had been run up which had been awarded against the son. After the costs and IHT paid on the failed PETs the son was in debt to the estate before any distribution was made.
The son claimed that the IHT due on the estate should be deducted...
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