A dwelling was a farmhouse eligible for agricultural property relief (APR), the farmhouse and other buildings at the farm were for the purposes of agriculture for APR purposes, and the business carried on by the deceased was eligible for business property relief.      

An individual (TG) died in November 2013, aged 79. He had lived at a farm. At the time of his death, TG owned the freehold to 11 properties (‘properties 1–11’). The appellants (TG’s executors) filed an inheritance tax account in respect of TG’s estate, which included claims for agricultural property relief (APR) and business property relief (BPR). 

The farm (property 1) was 22.72 acres in total, comprising the house in which TG lived, a yard, brick barn and other outbuildings, 21.19 acres of bare agricultural land (permanent pasture); and a separate range of adjacent