The first condition in IHTA84/S10 is that the disposition (IHTM04164) was not intended, and was not made in a transaction intended, to confer any gratuitous benefit on any person (IHTM04052). It is necessary for the person claiming that a disposition is within IHTA84/S10 to show that the transferor

sought to obtain the full open market price under the transaction, and

had no donative intent.

Example 1

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