Where land is acquired by inheritance or gift, liability will
not ordinarily arise under Case I in respect of its subsequent sale
(see Hudson's Bay Company v Stevens [1909] TC424 and Williams v
Davies [1945] 26TC371).
A possible exception to this general rule is where there is,
following acquisition, a change of intention, i.e. material
development takes place that constitutes a supervening trade (see
BIM60060).
