This appeal at the First Tier Tribunal (FTT) concerns whether the acquisition of a property was a chargeable transaction in which the relevant land consisted entirely of a residential property, or whether the interests in land was a ‘mixed-use’ acquisition.

Lesley Goudman-Peachey, executor of the estate of her husband, Paul Goudman-Peachey, appealed against an HMRC closure notice for £477,250 for additional stamp duty land tax (SDLT) for the purchase of a property.

The property was purchased for £7.9m and was a country estate at Woodmancote Place in Henfield, West Sussex, consisting of a main 10-bedroom house with two subsidiary dwellings, a swimming pool and equestrian facilities, all set in extensive grounds of 150 acres.