Summary 

An individual’s will gave a joint tenant-in-common an interest in possession of the deceased’s share of a property to her brother, which formed part of the life tenant’s estate for inheritance tax purposes on his death. 

Background 

In 1985, the appellant’s parents (Mr and Mrs H) and her uncle (IT) decided to sell their respective homes and buy a house together. The property was purchased for £125,000 on 30 August 1985 by the three purchasers. They intended to live at the property for the remainder of their lives. 

The costs of the building works and furnishings were added to the cost of the house, and the total was used to determine the total cost and their respective financial contributions. The sale proceeds of IT