In D & Mrs E Horner v HMRC (TC02498 – 13 February) a couple purchased a property which they intended to let as holiday accommodation in September 2004. Their first letting of the property did not begin until 9 July 2005. During the twelve months from 9 July 2005 to 8 July 2006 the property was only let for 64 days. The final letting ceased on 9 December 2006 and the couple sold the property in June 2007. HMRC issued assessments charging CGT on the sale. The couple appealed contending that the property should be treated as qualifying for business asset taper relief for their entire period of ownership. The First-tier Tribunal rejected this contention and dismissed the appeal holding that although it was accepted that the property had qualified as a business asset for 2006/07 it had not done...
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In D & Mrs E Horner v HMRC (TC02498 – 13 February) a couple purchased a property which they intended to let as holiday accommodation in September 2004. Their first letting of the property did not begin until 9 July 2005. During the twelve months from 9 July 2005 to 8 July 2006 the property was only let for 64 days. The final letting ceased on 9 December 2006 and the couple sold the property in June 2007. HMRC issued assessments charging CGT on the sale. The couple appealed contending that the property should be treated as qualifying for business asset taper relief for their entire period of ownership. The First-tier Tribunal rejected this contention and dismissed the appeal holding that although it was accepted that the property had qualified as a business asset for 2006/07 it had not done...
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