Theodore Wallace and Charles Hellier

Decision released 22 November 2006

Inheritance tax – Transfer by close company – Whether gratuitous benefit intended – Surplus funds wholly attributable to services of sole participator – Salary one-eighth of fees earned for company – Lump sum paid to FURBS – Death benefit for dependants – Whether shown that gratuitous benefit not intended – IHTA 1984 s. 10, 12, 13, 86, 94 – Appeal allowed

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