Dr Nuala Brice.

Decision released 25 October 2001.

Inheritance tax – Capital gains tax – Residuary bequests to charities and so no liability for tax on death – Sale of land within three years of death – Sale prices higher than open market value at date of death – Whether claim could be made sale values were value for purposes of inheritance tax – Whether sale values were ‘ascertained’ values and so deemed to be market values at date of death for purposes of capital gains tax – Inheritance Tax Act 1984, s. 190, 191 – Taxation of Chargeable Gains Act 1992, s. 274.

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