The appellants disposed of three properties in the year ended 5 April 2007, which had been purchased in their joint names. Each appellant’s tax return for that year did not disclose any disposal or capital gain for any of the three properties. HMRC raised discovery assessments and imposed penalties (under TMA 1970, ss 29 and 34). The appellants appealed.
The dispute for two of the properties (W and S) concerned the correct method of calculating the sale proceeds on the appellants’ disposal of the properties, and on what amounts properly fell to be deducted in calculating the net chargeable gain on disposal. The issues on the third property (B) included whether the gain on disposal qualified for private residence relief (under TCGA 1992, ss 222 and 223), and on whether painting and decorating costs were deductible in calculating the chargeable gain.
The FTT found in relation to properties W and S (among other things)
