Dorcas Adebowale Akanwo v HMRC
Decision date: 10 April 2018
Neutral citation: [2018] UKUT 113 (LC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This is an inheritance tax valuation dispute about 180 Morley Avenue, a two‑bed Victorian terraced house, as at the date of death 12 September 2012. The executor contended £200,000; HMRC/VOA (Mr Newell) valued it at £260,000 using a comparative sales approach with adjustments including a 5% reduction for an Assured Shorthold Tenancy. The tribunal accepted the VOA comparative analysis (correcting a typographical inspection‑date error) and fixed the market value at £260,000; no costs were ordered.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
A properly conducted comparative valuation based on contemporaneous local sales, with sensible adjustments for size, condition and tenancy, can establish market value for inheritance tax purposes; in this case the tribunal found a modest 5% reduction appropriate to reflect the diminution caused by an Assured Shorthold Tenancy.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The tribunal indicated that while an internal inspection is desirable, its absence does not necessarily invalidate a valuation if the comparative exercise is thorough and persuasive; it also suggested that informal estate‑agent appraisals unsupported by formal survey evidence carry limited weight against a detailed expert valuation.
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