1. At the time of her death Mrs B L Burkinyoung owned a house divided into four flats (‘property’). Letting the four flats was carried on by her as a business. This is common ground. The property will be ‘relevant business property’ for purposes of the inheritance tax charge at her death unless it is excluded by Inheritance Tax Act 1984 section 105(3). The question at issue is whether her business consisted wholly or mainly of ‘making or holding investments’; if so, its value will be excluded for purposes of business property relief.

2. The notice of determination appealed against was issued on 1 November 1993. It reads:

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