Commentary

I4.153 Non-deductible liability to donee―the rules in practice and Phizackerley

IHT, trusts and estates

I4.153 Non-deductible liability to donee―the rules in practice and Phizackerley

I4.153 Non-deductible liability to donee―the rules in practice and Phizackerley

The operation of FA 1986, s 103(1) (see I4.151, I4.152) is illustrated by McDougal's Trustees1 where the deceased had bought an estate for the City of Edinburgh to be used as a public park, and had borrowed the money for the purchase from the City. The court held that in view of FA 1939, s 31(1)(b)2 no deduction could be allowed for the money borrowed, as the City had amongst its resources the estate conveyed to it by the deceased. The matters in dispute arose for the most part out of the special status of the City as

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial