And quite rightly. See:
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10915/TC0...
https://www.step.org/news/seriously-derelict-houses-do-not-attract-highe...
https://www.rsmuk.com/blog/when-is-a-dwelling-not-a-dwelling
Not only does HMRC lose, the company actually ends up getting an SDLT refund!
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To summarise do no one else has to read it ...
Dilapidated bungalow bought to be demolished & rebuilt.
1. HMRC didn’t put all evidence in their submission
2. HMRC made irrelevant arguments to try and win points in court.
3. Retired RICS surveyor onnoanel said “clearly unsuitable as a dwelling”.
4. Taxpayer declared SDLT on property, not land, so was refunded.
Boom.
Good to see the judge calling HMRC on #1 & #2