You should probably also quote from the primary legislation. Section 131 of the Conts and Bens Act 1992:
subsections (1) & (3) say that the main condition of entitlement to CTB is that the claimant is liable to pay council tax for a dwelling of which he is a resident
subection (11) defines “dwelling” and “resident” as having the same meaning as they have in the Local Government Finance Act 1992 and in that context it is inevitable that you read “liable” as having the same meaning that it has in that Act as well.
The final clincher comes in s138 of the Administration Act: it only allows a CTB payment to exist in a case where the person is liable to pay tax to a “billing authority” – otherwise, there is no means of payment.
In short, he is not in a position where he can benefit from a payment of CTB.
No such thing as misconceived appeals any more…