Where, as a result of an omission by a person to exercise a right, his estate is diminished and that of another increased, this is treated as a disposition by that person, unless it is shown that the omission was not deliberate (IHTA 1984, s. 3(3)). The same applies where the omission results in an increase in the value of property in which no qualifying interest in possession subsists. What is envisaged here is purely negative action, or inaction, causing value to be transferred from one person's estate to another. Examples of omissions within s. 3(3)) are:
•failure to take up a rights issue, so that the holder is left with less valuable shares;
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