In this case, Revenue refused CAT dwelling-house relief (CATCA 2003 s 86) in respect of a gift of residential property on the basis that the beneficiary had an interest in other residential property at the time of the gift. The appellant did not (by virtue of CATCA 2003 s 43 or otherwise) hold a beneficial interest in property owned by a company he controlled.  The Commissioner determined the appellant was entitled to dwelling-house relief.