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D Regan v HMRC

In D Regan v HMRC (TC02247 – 26 September) an individual (R) purchased a house in 1994. He renovated the house and took in a married couple as lodgers. In 1998 he purchased a house with his girlfriend and moved into it. He sold his old house to his parents in 2000. HMRC issued an assessment charging CGT on the gain on the sale. The First-tier Tribunal allowed R’s appeal finding that he had occupied the house as his principal private residence. (The appellant here was the son of the appellants in case TC02246 see J & Mrs S Regan v HMRC.)

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Why it matters: HMRC formed the opinion that the appellant had purchased the house for the purpose of renovating it and making a gain on its sale and issued a CGT assessment. HMRC placed considerable emphasis on the...

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