An appeal seeking to challenge a property valuation giving rise to a capital gains tax liability following a contract settlement was struck out, as the First-tier Tribunal did not have the necessary jurisdiction in relation to contract settlements.
An individual died in January 2005. He left his estate on trust for his four sisters, including the first appellant. The estate included a farm, which was valued upon death for inheritance tax (IHT) purposes at £650,000. No IHT was payable as the estate was below the nil rate band after taking into account agricultural property relief. In or about March 2006, the farm was sold by public auction for £800,000.
In July 2009, the second appellant submitted an estate return to HM Revenue & Customs (HMRC) claiming capital losses of some £18,000, on the basis of a claim under IHTA 1984, s 191 that the sale proceeds be substituted for the probate value on death.<>
