The appellant lived in a property (WH) in London. In February 1994, the appellant purchased another property in London (HM) for £175,000. Once purchased, the appellant carried out extensive renovation works to HM, which lasted until February 1995. From 1995 until early August 2013, the appellant let HM to tenants.
In February 2014, the appellant sold the property for a substantial gain. In her self-assessment return for the tax year 2013/14, the appellant claimed that the amount of the gain chargeable to CGT was reduced by principal private residence (PPR) relief (under TCGA 1992, ss 222 and 223), on the basis that HM was her main residence for the last six months of her ownership (i.e. 14 August 2013 to 23 February 2014). However, HMRC refused the PPR relief claim. The appellant appealed.
The First-tier Tribunal (FTT) found that the appellant had not proved, on the balance of probabilities, that she occupied HM as a residence
