The taxpayer’s appeal against the rejection by HM Revenue and Customs (HMRC) of a claim for principal private residence (PPR) relief was dismissed, as there was no evidence that the taxpayer had occupied the dwelling as her only or main residence at any time during her period of ownership.

Background

On 18 December 2001, and following her divorce, the appellant purchased a property (CC). She moved into it with her daughter (V). A few years later, the appellant’s widowed sister (BO) moved in with her. In 2010, V moved to Paris to live with her French boyfriend, and they decided to get married in late 2012. They married on 15 June 2013.

In 2011, the appellant met a wine merchant (PDD) living and working in France, and they fell in love. At some point in 2012 or early 2013, the appellant suggested to PDD that he close