Bankruptcy did not affect taxpayer’s liability

In July 1997 the taxpayer inherited a property from his mother – it was valued at £55 000. Three years later he was made bankrupt and beneficial ownership of the property vested in his trustee in bankruptcy. In 2003 the taxpayer was discharged from bankruptcy.

In May 2016 for the sum of £1 the taxpayer granted an option to a company to buy the property for £215 000. The company exercised the option September 2016. The taxpayer did not declare the capital gain on his self assessment tax return. After an enquiry HMRC assessed the taxpayer to capital gains tax. The taxpayer appealed on the basis that he was liable to tax on the disposal only while he was the beneficial owner. He reacquired ownership of the property only a short time before the date of disposal during which time there was no...