## Facts

- The case concerned whether Mr. Morgan’s property qualified as his main home for the purposes of Capital Gains Tax (CGT).
- The First-tier Tribunal reviewed the practical and factual circumstances of Mr. Morgan’s use of the property.
- Factors examined included the duration and frequency of stays at the property, utility usage, presence of furniture, access to essential services, and proximity to family and work.
- Documentary evidence, such as utility bills, council tax records, bank statements, and mail addressed to the property, was considered to support the claim of main home status.
- The tribunal referenced established HMRC guidance and prior legal decisions, such as Goodwin v Curtis, to inform its findings.

## Issues

1. Whether Mr. Morgan’s property qualified as his main home for the purposes of Capital Gains Tax.
2. What factual indicators and evidence are determinative in establishing a taxpayer’s main home for Principal Private Residence (PRR) relief.
3. The role of stated intention versus documented evidence in deciding main home status.

## Decision

- The tribunal concluded that no single factor is determinative; the outcome depends on a balanced assessment of relevant factual circumstances.
- Regular and extended stays, consistent use of utilities, and presence of essential amenities supported the claim of main home.
- Written, documentary evidence was deemed critical in substantiating claims of main home status rather than mere assertions of intent.
- The tribunal’s decision was consistent with previous case law and existing HMRC guidance.

## Legal Principles

- Determination of a main home for CGT purposes requires consideration of the actual use and connection to the property.
- Documentary evidence, such as utility bills and presence of personal effects, is essential in proving main home status.
- Stated intentions carry less weight than documented, factual indicators of use.
- Reliance on HMRC guidance and precedent ensures consistency and predictability in applying PRR relief.

## Conclusion

Morgan v HMRC [2013] UKFTT 181 (TC) established that documentary and factual evidence, not mere ownership or stated intent, are key in determining a taxpayer’s main home for CGT, reinforcing the importance of records and legal precedent in Principal Private Residence claims.