Joyce and Sybil Burden are unmarried sisters. They are aged 88 and 81 respectively, and for the past thirty years have lived in a house built on land inherited from their parents. If each leaves their share of the house and other property to the other by will, the house might have to be sold in order to pay the inheritance tax. This is charged at a rate of 40% under the Inheritance Tax Act 1984 (Inheritance Act 1984, ss. 3, 3A and 4), although it should be borne in mind that the actual likelihood of the house having to be sold has been doubted (See "Editor's Note" in [2006] 9 I.T.L.R 535, 537-538). The same level of tax would be payable if one sister transferred the house to the other inter vivos, and then died within seven years of doing so.