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Moore v Revenue and Customs: FTTTx 21 Sep 2010

FTTTx CAPITAL GAINS TAX – Relief on disposal of private residence – section 222 TCGA – whether property occupied by the Appellant was at any time in his period of ownership his only or main residence – period of occupation in question was less than 3 months immediately after purchase and was spent by the Appellant in effecting renovations – held on the facts that the occupation lacked the assumption of permanence, degree of continuity and expectation of continuity that would turn it into ‘residence’ – property subsequently let out and Tribunal found that the Appellant’s intention was to renovate it for letting and not for residence – Appeal dismissed

John Walters QC
[2010] UKFTT 445 (TC)
Bailii
England and Wales

Capital Gains Tax

Updated: 02 November 2021; Ref: scu.426583

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