Commentary

I8.203A CTT/IHT decisions on the Crossman principle

IHT, trusts and estates

I8.203A CTT/IHT decisions on the Crossman principle

I8.203A CTT/IHT decisions on the Crossman principle

The generality of the Crossman principle1 and its relevance to CTT/IHT is shown by two subsequent cases.

Baird v IRC

In Baird2 it was held to apply to a non-assignable agricultural tenancy, so that the amount a purchaser would pay to have the tenancy subject to the covenant against alienation was determined, and the fact that it was not assignable by the deceased was disregarded.

Alexander v IRC

In Alexander3 the position was more complicated and the application of the principle less obvious. The deceased owned a long leasehold which had been bought within

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