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Wills and Probate

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09 August 2007
Issue: 7285 / Categories: Features , Wills & Probate
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FROM THE REVENUE

The PRs of Harry Dexter Lyon deceased and the Trustees of the Alloro Trust v HMRC Spc 616, 21 May 2007

The trustees of the Alloro Trust (the trust) appealed against HM Revenue & Customs’ (HMRC’s) notice of determination that the property held at the date of death by the trust should be treated as property to which Mr L was beneficially entitled. The amount of tax in dispute was about £200,000. The relevant legislation was the Inheritance Tax Act 1984, ss 4 and 5 and the Finance Act 1986 (FA 1986), s 102.

Mr L gifted £2.7m to the trust, of which he was in the class of potential beneficiaries and received distributions totalling £15,965 during his lifetime.
The issue was whether or not the fact that Mr L was in the class of discretionary beneficiaries meant there was a reservation of benefit within the meaning of FA 1986, s 102(1).

The special commissioner made the following findings of fact:
- Mr L was one of the beneficiaries of the trust set up by

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