The taxpayer was not entitled to private residence relief on the disposal of a property because she did not occupy it with the intention that it would be her permanent home.

Background

The appellant owned a house in London from 14 July 2006 to 12 July 2007, although she did not gain entry to the house until 28 August 2006 (because the property was initially occupied by a tenant), and she decided to sell it by 28 March 2007 following a failed planning permission application.

The purchase price of the house (£190,000) was financed by borrowings from her mother in the first instance, and with bank borrowings of £125,000 as a one-year loan.

The appellant was a student. In mid-September 2006, she accepted the offer of a room in a student hall of residence in Southampton. Thereafter, the appellant began using her halls of residence address as her postal address. She stayed at the house in London (which was initially in