The appellants took reasonable care in relying on professional advice, which was subsequently found to be incorrect.

The appellants owned a property (ST), which was let to tenants until June 2010. The property was put up for sale, and contracts were exchanged on 25 May 2010. Completion took place on 23 July 2010.

The appellants moved into ST on 29 June 2010, and resided there until 22 July 2010. On the advice of their accountants at the time, the appellants executed a principal private residence election for capital gains tax (CGT) purposes on 23 April 2012, to the effect that ST was their principal private residence until 22 July 2010. By an election signed on the same date, the appellants elected another property (FR) as their principal private residence from 30 June 2010. The appellants subsequently filed tax returns in which they each declared their appropriate capital gains on the property disposal, as reduced by private