The case of David Michael Fryer and others (Personal Representatives of Patricia Arnold Deceased) v Revenue and Customs Commissioners [2010] UKFTT 87 (TC) (‘Fryer’) was one where the deceased had omitted to take her pension rights at her normal retirement date at a time when she was terminally ill. The decision was that there had been an omission to exercise a right that was treated as a disposition made immediately before death. Mrs Arnold died on 30 July 2003. The case is very useful for the observations on IHTA84/S3(3) and on IHTA84/S10. The case also provides judicial support for the HMRC approach to the valuation of pension rights.

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