Court of Session (Inner House).

Lord President Hope, Lord Sutherland and Lord Clyde.

Judgment delivered 30 August 1990.

Stamp duty – Voluntary disposition of estate by owners to Jersey company – Purported grant of lease by estate owners to nominee for themselves before disposition – Purported lease assigned by nominee to owners after disposition – Whether lease a nullity – Whether stamp duty chargeable on value of property subject to lease or, if lease ineffective, on higher value of property free of lease – Finance (1909-10) Act 1910, sec. 74(1) (Repealed by Finance Act 1985, sec. 82(1)).

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