Dr P Broome v HMRC

In Dr P Broome v HMRC (TC01597 – 6 December) a doctor (B) had been born in England in 1949 and was resident in the UK until 1977 and from 1980 onwards. He married in 1989 but divorced in 1999. He disposed of two properties in 2000/01 but failed to declare the gains on his tax return. Following an enquiry HMRC issued a jeopardy amendment charging tax on the gains. B appealed contending that he had ceased to be resident in the UK after his divorce. The First-tier Tribunal reviewed the evidence in detail rejected this contention and dismissed his appeal finding that he had purchased a property in France in April 2000 but had made several return visits to the UK. Judge Connell noted that B had subsequently sold his French property and had told the French revenue...