Goodwin v Curtis (Inspector of Taxes)

JurisdictionEngland & Wales
Judgment Date23 July 1996
Date23 July 1996
CourtChancery Division

Chancery Division

Before Sir John Vinelott

Goodwin
and
Curtis (Inspector of Taxes)

Capital gains tax - private residence relief - short period of occupancy

Capital gains tax relief lost through short occupancy

To qualify for private residence relief from capital gains tax an individual's residence in the property had to have a degree of permanence and expectation of continuity. The relief was not available in respect of the gain accruing to the taxpayer on the sale of a farmhouse purchased by him and in which he had lived for only a short time.

Sir John Vinelott, sitting as a judge of the Chancery Division, so held dismissing an appeal by the taxpayer, Mr Charles Paul Goodwin, and upholding a determination by Cirencester general commissioners that the relief given by section 101 of the Capital Gains Tax Act 1979 was not available in respect of the gain accruing on the sale in 1985 of Hazleton Manor Farmhouse.

Section 101 of the 1979 Act provides for relief on a gain accruing to an individual on the...

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1 cases
  • Goodwin v Curtis (Inspector of Taxes)
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 18 February 1998
    ...Act 1992 section 222Taxation of Chargeable Gains Act 1992, s. 222). This was an appeal by the taxpayer against a judgment of Sir John Vinelott [1996] BTC 501 dismissing his appeal from the decision of the general commissioners for Cirencester that occupation of a house for five weeks did no......