The appellant, James George Gibson, appealed against a closure notice issued by HMRC last year, which was in the sum of £83,000 related to SDLT.

It was issued to Gibson about a property called Doe Bank Manor, which was purchased for £1,595,000 on 10 January 2019.

Gibson, and his wife and children, were in occupation of the property on 27 November 2018 but for several reasons, the completion date was delayed to January 2019.

The property comprised of a six bedroom house, a double garage with an office above, and a two bedroom self-contained barn with two bathrooms, open plan living, dining and kitchen area. It also contained two stables, and a paddock of approximately two acres.