On the purchase of a house and land all the land was, or formed part of, the garden or grounds of a dwelling and no claim to multiple dwellings relief could be made as the time limit had expired.

The appellant appealed against a closure notice issued by HM Revenue and Customs (HMRC) on 24 January 2022, for stamp duty land tax (SDLT) in relation to a residential property in Warwickshire purchased on 10 January 2019. The appellant confirmed that he, his wife and children were in occupation of the property on 27 November 2018 but for various reasons the completion date was delayed to 10 January 2019. 

The property comprised two Land Registry titles (WK425880 and WK426348). The former comprised: (1) a six-bedroom house over two storeys; (2) a double garage with an ‘office/studio’ above it, accessed by an external staircase; (3) a two-bedroom self-contained barn with two bathrooms, open plan living, dining and kitchen area and a mezzanine