THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v (1) GERALD LEE (2) SARAH LEE [2023] UKUT 00242 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN & JUDGE NICHOLAS ALEKSANDER on 29 September 2023
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CAPITAL GAINS TAX – Private Residence Relief – taxpayers bought land demolished existing house and build new dwelling house which they lived in as main residence then sold for gain – meaning of “period of ownership” used in apportionment relief – held - ownership referred to that of new house as opposed to land as HMRC argued – HMRC’s appeal against FTT decision dismissed