The Upper Tribunal (Lands Chamber) determined that the market value of land for inheritance tax purposes on the date of an individual’s death was lower than the valuation used in HMRC’s determination but higher than the valuation advanced by the deceased’s executor. 

At the date of the deceased’s death (26 August 2013), her estate included 6.39 acres of unregistered freehold agricultural (pasture) land in Shropshire (‘the site’). There was a dispute between the appellant (the deceased’s executor) and HM Revenue and Customs (HMRC) about the open market value of the site for inheritance tax (IHT) purposes. The appellant, upon professional advice, valued the land at £191,700, while HMRC upon the advice of the valuation office agency (VOA) valued it at £850,000. The appellant appealed against HMRC’s determination of IHT.