Summary
The valuation of a property interest for inheritance tax purposes (under IHTA 1984, s 160) was required to take account of ‘hope value’ as an element of market value.
Background
The deceased (AP) owned an 88.4% share in the long leasehold interest in a maisonette, together with a one-third share of the freehold of the building in which it was located. AP died in June 2012.
In December 2016, HM Revenue and Customs (HMRC) served an inheritance tax notice of determination (under IHTA 1984, s 221) on the appellant (AP’s son and personal representative), under which AP’s property interest was valued at £1,829,880. The appellant appealed, on the basis that the correct valuation was £1,113,840.
The appellant had instructed a valuer to value the property for probate purposes. In August 2012, the
