Purpose of occupation

The taxpayer was divorced in 1997 and soon afterwards learned that he would be made redundant in 1999.

As he believed he would be unable to meet his financial commitments he decided to sell the former matrimonial home and buy another property. He sold the property in November 1998 and moved in with his brother.

However he gave HMRC the address of his secretary with whom he was having a relationship.

In November 1999 having been made redundant the taxpayer bought a property for £47 000. It required a lot of renovation which the taxpayer did himself. From July 2000 he let the property to students. He began full-time employment in September 2003 and sold the property two years later. He claimed only or main residence relief for the period between November 1999 and September 2000 on the gain.

The...