Inheritance tax

In the light of established authority, the statutory test of holding an investment was not a term of art, and should be given the meaning that would be given by an intelligent businessman and, just because the person holding it had to take active steps did not prevent it being an investment. Where a landowner derived income from land he would be treated as having a business of holding an investment notwithstanding that in order to obtain the income he carried out incidental maintenance and management work, found tenants and granted leases. The relevant test was not the degree or level of activity, but rather the nature of the activities which were carried out.