A property was held to be an individual’s ‘residence’ for private residence relief purposes, albeit that the property was only occupied for a brief period in the individual’s period of ownership.
The appellant and his partner bought a house in Maidstone. The appellant had a successful property business. His company acquired a property in Farnham, Surrey (known as ‘Richmond’) in February 2008.
It was always intended that Richmond would be a family home. The appellant moved some furniture from Maidstone into Richmond. His children lived with him in the property for two and a half months. He intended to take out a mortgage, buy the property from the company and live at Richmond.
However, following the financial crash of 2008, the only mortgage available was on a ‘buy-to-let’ basis, under the terms of which he would be forbidden from living in the property. The
