The First Tier Tribunal ruled that the ‘annex is not usable as a single dwelling’ and as a result was not eligible for the tax break on stamp duty land tax. 

The appellant Yispoel Dreyfus, director of property lettings agency Triplets Estates Limited, launched an appeal against HMRC’s closure notice in 2023 but was 13 days late in doing so. HMRC and the tribunal allowed the appeal to go ahead despite the late appeal.

Additionally, Dreyfus filed his skeleton argument two days late, and then HMRC attempted to get the appeal struck out, but this was thrown about by the tribunal and the appeal went ahead.