A property was held to be in the sole beneficial ownership of an individual upon death, and money in a bank account was held to be jointly owned by the deceased and his son.
The appellant (BSL) was the sole executor of the estate of his father (BL), who died in March 2007. BSL submitted a short IHT account (IHT205) to HM Revenue and Customs (HMRC), indicating that the net value of BL’s estate was £261,059 (i.e. below the applicable IHT threshold of £285,000).
HMRC subsequently wrote to BSL stating it was in possession of information suggesting that BL’s estate was above the IHT threshold. HMRC required BSL to submit a full IHT account (IHT400). The completed IHT400 showed a net estate value of £307,408, which included 50% percent of money held in a bank account, and a 50% beneficial interest in a property.
HMRC issued an IHT determination of £57,532, on the basis
