The deceased taxpayer owned shares in a company which operated a residential caravan park. The company collected pitch fees for parking caravans at the park and also bought and sold caravans. The executors of the estate claimed business property relief for inheritance tax purposes in respect of the shares in the company but the Inland Revenue denied the claim contending that the shares were not eligible on the grounds that the main business of the company was holding investments.
It was held that the business was that of making investments as the income was derived mainly from selling rights to use the land. BPR was therefore denied.