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Changizi v Changizi and others

This is not a tax case as such, but we refer to it briefly because it will be of interest to IHT practitioners.

The context is a dispute between mother and son as to how the burden of the IHT liability should be met. The situation is complex and has already been the subject of considerable litigation, but essentially the son was arguing that the IHT should be a charge on the estate whereas the mother argued that as the spouse of the deceased she was an exempt beneficiary and therefore the liability should fall entirely out of the son’s share of the estate.

The court agreed with the mother and the reasoning at paras 28 onwards sets out the analysis in a very clear way.

Patel v HMRC

This case deals with a familiar SDLT question: what is a residential property?

At the date of purchase the property here was essentially a building site where two large, conjoined houses, which had been unoccupied