Ownership is not enough

The appellant’s father bought a property in Lancaster and lived in it until 1996. It was used as a holiday home until 1997.

The appellant intended to live in the property from 1998 while studying at Lancaster University but she changed her mind and took a course in Leeds instead. The father transferred the property to the appellant in 1998 and it was let until 2002.

The appellant sold the property in 2003. She claimed it was her main residence from 1998 to 2003 although she spent virtually no time living in it because she was at the Universtity of Leeds between 1998 and 2002.

She said she had intended to live in the house after her course finished but she got a teaching post in Leeds and did not move back to Lancaster.

Alternatively she claimed no capital gains tax was...