The Upper Tribunal has partly allowed an appeal against a number of issues arising on the disposal of four residential properties in the case of Campbell v HMRC  UKUT 00265 (TCC).
“This appeal relates to the tax liability of Mr Campbell in respect of four residential properties which he sold between 2010 and 2016. The substantive issue is whether he was liable to capital gains tax (“CGT”) on the disposals, or to income tax, or to neither. There are also procedural issues as to the validity of the tax assessments issued by HMRC, and a challenge to the quantum of the penalties imposed by HMRC.
Mr Campbell appeals against the decision of the First-tier Tribunal (the “FTT”) released on 8 February 2022 (the “Decision”), and HMRC cross-appeal against one aspect of the Decision.”
The full judgment can be found at https://assets.publishing.service.gov.uk/media/6545013659b9f5000d85a23a/Mark_Campbell_final_decision_002_.pdf.
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