This case looked at the principle of private residence relief, short occupation and the intention to occupy as a main residence
A company acquired a farm that included a nine-bedroom farmhouse.
It was agreed that, following completion of the purchase, it would sell the farmhouse to one of its directors.
Completion of the purchase took place approximately two years later, at which point the director was in the process of separating from his wife and had acquired a small cottage.
Shortly thereafter, the sale of the farmhouse was completed and he moved into the cottage. He claimed principle private residence relief on the sale of the farmhouse.
It was held that principle private residence relief was not due as he had only lived in the farmhouse for 32 days and it had never been his intention to occupy the property as his permanent residence.