The taxpayer’s occupation of two properties for approximately four and six months was not sufficiently permanent to constitute residence, and it was more likely the properties were bought and sold because the taxpayer saw an opportunity to make a profit. 
 
The appellant (an estate agent) resided at the matrimonial home in Peterborough with his wife and two children. In 2005, he moved out of the house due to matrimonial difficulties. He moved to another address in Peterborough (‘Regents Court’), which he purchased on 31 December 2005 for £82,500. He sold Regents Court on 29 March 2006 for £93,000, after finding the property unsuitable.  
 
The appellant returned a capital gain on Regents Court of £10,500 on his self-assessment return for the tax year 2005/06. He did not seek to claim that Regents Court was his principal private residence, on the basis that it was only a