Lack of evidence of occupation to support main residence exemption

In the period 2013 to 2015 the taxpayer bought and sold several properties. She claimed to have lived in three of them as her main residence. HMRC was not satisfied with the evidence produced in support of this and raised capital gains tax assessments in respect of each sale.

The taxpayer appealed.

The First-tier Tribunal said it was clear the taxpayer was trading in property. She had undertaken six conveyancing transactions for each of the properties in the appeal but she had also carried out another four in relation to two other houses. Further photographs showed that improvement works were undertaken during the period of ownership which would have made the buildings unsuitable for habitation by a young family. In terms of evidence of occupation the taxpayer had produced inadequate proof of residence such as utility bills to show she had lived in the properties with...