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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 referred to two sentences in an...

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