Where the value of property – most often land and
buildings – has been established for IHT purposes, that
valuation is binding on both sides and must be adopted by both
HMRCand the beneficiary in determining the latter’s
acquisition cost for capital gains tax purposes.
The term ‘ascertained’ has no statutory
definition, but the judgement in the case of Stonor and Mills
(executors of Margaret Evelyn Dickinson) v CIR (2001) STC (SCD) has
approved our approach, which is that for a value to be ascertained
some formality or agreement is required and a simple claim is not
sufficient.
