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THE

SCOTS LAW TIMES

REPORTS

1924

EDINBURGH

PUBLISHED BY W. GREEN & SON, LIMITED, AT THE OFFICE

2 AND 4 ST GILES STREET

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REPORTS

1924, SCOTS LAW TIMES

REPORTED BY

W. R. GARSON, Esq.; MARCUS DODS, Esq., B.Α.; MAURICE J. KING, Esq., M.A., LL.B.; J. A. LILLIE, Esq., M.A., LL.B.; WILLIAM GARRETT, Esq., B.A., LL.B.; M. G. FISHER, Esq., M.A., LL.B.; J. MACGREGOR, Esq., M.A., LL.B.; And T. GRAINGER STEWART, Esq., ADVOCATES.

NOTE.-Cases in this volume may be cited 1924, S.L.T.

Thus:

Inland Revenue v. Fothringham, 1924, S.L.T. 2.

REPORTS

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granted leave to reclaim. His Lordship's opinion is printed in the previous report.

The Lord Advocate reclaimed, and the case was heard before the First Division on 23rd and 24th October 1923.

Argued for the Pursuer: The modus calculandi of the statute was to ascertain the number of years' purchase at which the property was valued and use that number as the multiplier of the amount of the annuity. The question had never been raised whether, in ascertaining the number of years' purchase of the property, it was legitimate to deduct a sum in name of

Revenue-Estate duty-Property passing on death
Heritable estate-Cesser of interest in property by
death-Interest extending to less than the whole
income of the property-Value of the benefit
accruing or arising-Finance Act, 1894 (57 & 58
Vict. cap. 30), section 7 (7) (b)-“....the the annual cost of repairs from the gross
principal value of an addition to the property rental. (If such a deduction were made, as
equal to the income to which the interest the capital value of the property was an agreed
restricted to £4000 Ascertainment of number value, obviously the number of years' purchase

extended "-Cesser of an "Aberdeen Act" annuity

of years' purchase of the whole property by which
to multiply annuity-Agreed principal value of the
whole property-Legitimacy of deductions from the
purchase at which the whole property was so valued
-Repairs-Held (reversing Lord Blackburn, Lord
Skerrington dissenting) that an agreed sum in name
of annual repairs was a legitimate deduction from
the gross rental in ascertaining the number of years'
purchase at which the whole property was valued
and at which the annuity fell to be valued for

gross rental in ascertainment of number of years'

was increased, and in the result the capital value of the annuity was also increased.) The deduction was a proper one, because what had ultimately to be valued was the capital of a charge-free annuity. The rental of the property used in the calculation must, therefore, also be a charge-free rental. An annuitant had an interest in the repairs of the estate on which the annuity was secured, since if the estate were not properly kept up the annuity might possibly have to be curtailed. It was, therefore, necessary to figure a hypothetical addition to the property which yielded after deduction for repairs a free annuity of £4000. Thus it Reclaiming Note against an Interlocutor of Lord was fair and right to deduct repairs from the Blackburn.

purposes of estate duty.

(Reported ante, sub. nom. Lord Advocate v.
Fothringham, 1923, S.L.T. 487.)

The Lord Advocate, on behalf of the Commissioners of Inland Revenue, brought an action of accounting and payment, inter alia, of estate duty against Walter Thomas James ScrymsoureSteuart Fothringham of Pourie and Grandtully. The conclusions of the action, the pleadings of the parties, and the relevant sections of the Finance Act, 1894, are all sufficiently set forth in the previous report.

On 8th June 1923 the Lord Ordinary (Blackburn) sustained the second and third pleas in law for the defender, continued the cause, and

gross rental of the actual property before calculating the number of years' purchase at which it was valued. Counsel referred to the following authorities: Attorney-General v. Coole, [1921] 3 K.B. 607, per Sankey J. at p. 618; Edinburgh and Glasgow Railway Co. v. Hall, 1866, 4 M. 1006, per Lord Justice-Clerk Inglis at p. 1008; Attorney-General v. Power, [1906] 2 I.R. 272, per Palles C.B. at p. 277 ; In re Elwes, 1858, 3 H. & N. 719, per curiam (Watson B.) at p. 716; Lord Advocate v. Henderson's Trs., 1905, 7 F. 963; Lord Advocate v. Maclachlan, 1899, 1 F. 917, per Lord President Robertson at p. 922, Lord Adam at p. 923,

REPORTS-1924, SCOTS LAW TIMES.

3

and Lord M'Laren at p. 924; In re Earl upon the principal value of all property which IST DIV.

Cowley's Estate, [1898] 1 Q.B. 355, per A. L.
Smith L.J. at p. 367.

Argued for the Defender: This was a taxing statute and in dubio must be construed in favour of the subject. There was no authority beyond the ipse dixit of the Commissioners that the word "income" in section 7 (7) of the Finance Act of 1894 meant income

passes on the death of such person; and, by Inland
subsection (1) (b) of section 2, "property Revenue v.
passing on the death of the deceased" is deemed Fothring-
to include "property in which the deceased or ham.
any other person had an interest ceasing on the November 17
death of the deceased to the extent to which
a benefit accrues or arises by the cesser of such
interest."

after deduction for repairs. It was equally Accordingly, the Murthly property must be

open to the defender to assert that the word meant gross income, and perhaps he had conceded too much in not stating his objection to the deduction even of public burdens. If the contention of the Crown was right, why did the Commissioners stop at repairs? They might with equal logic have deducted the cost of insurance and management. But the defender had conceded the deduction of public burdens because they constituted a charge upon income prior to the annuity. The cost of repairs was not prior to the annuity. The interest of the deceased here was £4000 per annum, nothing more and nothing less. She had no concern with the repairs to the whole property. The benefit accruing to the defender was also £4000 per annum, neither more nor less, and the number of years' purchase at which that benefit should be valued must be ascertained by a consideration of the true annual

a

deemed to have passed on the death of Lady
Douglas Stewart to whatever extent (if any) a
benefit arose or accrued by the cesser of her
interest. The question whether
benefit
has or has not arisen is crucial to the incidence
of estate duty. If no benefit arose, there is no
property subject to duty. It is obvious prima
facie that some benefit did arise or accrue in
respect of the release of a property worth
nearly £240,000 and having a rental of over
£13,000 gross, or £10,000 net (that is, after
allowing for public burdens together with ordin-
ary and necessary repairs), from the burden
of an annuity of £4000. The next question,
closely related to the first, is: What was the
extent of the benefit? This is a question of
valuation; and the statute provides, in sub-
section (7) of section 7, two special rules, (a)
and (b), for valuing the benefit. Which of
these two rules is applicable in any given case

value of the whole property to him. That depends-according to their terms-on the

annual value was the gross rental less public burdens. It was out of that annual value that he had to keep his property in repair. Besides, the cost of repairs had been already allowed for in fixing the number of years' purchase at which the whole property was valued. That calculation always included as a factor in it the state of the property. Counsel referred to the following authorities, in addition to those cited for the pursuers: Earl of Galloway v. Dowager Countess of Galloway, 1903, 6 F. (H.L.) 1; In re Parker-Jervis, [1898] 2 Ch. 643. [Lord Skerrington referred to AustenCartmell on the Finance Acts, p. 80.]

Avizandum, 24th October 1923.

On 17th November 1923 the Court recalled the interlocutor of the Lord Ordinary, sustained the fifth plea in law for the pursuer, and remitted to the Lord Ordinary to proceed.

The Lord President (Clyde). The late Lady Douglas Stewart was entitled to an annuity secured over the property of Murthly. The interest which, as annuitant, she had in the property ceased on her death on 6th October 1916. By section 1 of the Finance Act, 1894, estate duty is payable in the case of every person dying after the commencement of the Act

result of a comparison between the extent of
the deceased's life interest and "the whole
income of the property." Rule (a) applies to
the case in which the "interest extended to the
whole income of the property"; and directs
that the value of the benefit arising or accruing
from the cesser of the interest shall be taken to
be "the principal value of the property "-
which means (according to subsection (5) of
section 7) the market value of the property
as at the death of the deceased. Rule (b)
applies to the case in which the "interest
extended to less than the whole income of
the property," and directs that the value
of the benefit shall be taken to be "the
principal value of an addition to the property
equal to the income to which the interest
extended."

The whole dispute between the parties is as
to the meaning of the word income occurring
in these rules. The revenue maintains that
by income the net income-after deduction of
public burdens together with ordinary and
necessary repairs-is meant. The Lord Ordin-
ary has held that what is meant is the net
income-after deduction of public burdens
only. The respondents, while they did not
challenge the Lord Ordinary's findings, argued-
after some hesitation that the true construc-
tion to be put on the word income is gross

1923.

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