Property was suitable for use as a dwelling

In 1979 the owners of a listed residential property sold the main house to a company Cruden which converted it into offices as its corporate headquarters. An annex remained in residential use and was occupied by a caretaker until 1991.

In 2018 the company decided to sell the property and the sales brochure described it as ‘in office use’ but that its potential uses included a private residence. In 2019 the company applied for and obtained permission for change of use from office to residential.

The taxpayers had viewed the property in 2018 with a view to making it their main residence. They made an offer but it was not accepted. Eventually after other potential buyers fell through the taxpayers made an offer conditional on planning permission for the property. This was accepted and the transaction was completed in April...