Discovery assessment and principal residence relief
In K Lo v HMRC [2018] UKFTT 605 (15 October 2018) the FTT found that the appellant was not entitled to private residence relief (TCGA 1992 s222) on the sale of a property and that the discovery assessment raised by HMRC (TMA 1970 s 29) was valid.
Ms Lo had purchased a derelict flat and then sold it a few years later. She had not filed a return on the basis that principal private residence relief applied. She now appealed HMRC’s decision to issue a discovery assessment imposing a CGT charge.
Ms Lo contended that the discovery had become stale by the time the assessment was raised. The parties agreed that there had been a discovery but disagreed as to its timing. The assessment had been raised in January 2015 and Ms Lo contended that the discovery had been made in 2012. She...
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Discovery assessment and principal residence relief
In K Lo v HMRC [2018] UKFTT 605 (15 October 2018) the FTT found that the appellant was not entitled to private residence relief (TCGA 1992 s222) on the sale of a property and that the discovery assessment raised by HMRC (TMA 1970 s 29) was valid.
Ms Lo had purchased a derelict flat and then sold it a few years later. She had not filed a return on the basis that principal private residence relief applied. She now appealed HMRC’s decision to issue a discovery assessment imposing a CGT charge.
Ms Lo contended that the discovery had become stale by the time the assessment was raised. The parties agreed that there had been a discovery but disagreed as to its timing. The assessment had been raised in January 2015 and Ms Lo contended that the discovery had been made in 2012. She...
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