In Trevor Anthony Hartland v HMRC [2014] UKFTT 1099 (16 December 2014) the FTT found that private residence relief from CGT was not available.
Mr Hartland bought a property obtained planning permission for an extension completed the works and sold it. Two days later he acquired another property which he occupied for two years before selling it. He then acquired a third and a fourth property which he then sold.
He claimed that each of the properties had successively been his homes and that they were not assets in which he was trading. However he accepted that other property transactions entered into around the same time had been in the nature of a trade. HMRC contended that all the property transactions entered into by Mr Hartland had been in the nature of a trade.
On the basis of the evidence the FTT accepted that...
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