TC09658 - [2025] UKFTT 01210 (TC)

The burden of proof is on Mr Town to establish that on a balance of probabilities the Property is comprised of three single dwellings. HMRC accept that Springwood House and Springwood Cottage are each single dwellings. Mr Town must therefore establish that on a balance of probabilities, the Summerhouse was suitable for use as a single dwelling on the EDT.