The dispute centred on a substantial inheritance tax (IHT) dispute with HMRC over a refusal to accept a claim for business property relief (BPR) under section 105 Inheritance Tax Act 1984, resulting in a tax bill for £1,168,801.

The demand was issued to the executors of Gertrud Tanner’s estate by HMRC on 4 November 2020, and was disputed by the sole beneficiary Ms Foster.

The First Tier Tribunal (FTT) heard that when Gertrud Tanner died in 2017, she was the owner of five self-catering holiday lets in Whitby, Yorkshire, which were valued between £290,000 and £450,000, amounting to £2,040,000 in total.

As well as the holiday lets, Tanner owned The Railway Cottage, a derelict building valued at £230,000, but there were plans to turn this into accommodation.