Mr THK Everett.

Decision released 10 April 1997.

Capital transfer tax – Personal liability of executors – Balance of tax outstanding but property transferred to executor who was a beneficiary – Bankruptcy of executor beneficiary – Revenue unaware of bankrupcy – Revenue sought to recover unpaid tax from another executor who was not a beneficiary – Delay by Revenue in registering a land charge against deceased’s property – Whether delay on part of the Revenue relieved executor of liability – Appeal dismissed, Revenue under no obligation to register land charge – Capital Transfer Tax Act 1984, s. 221, 237, 238.