Court of Session (Outer House).

Lord Coulsfield.

Judgment delivered 26 November 1991.

Capital transfer tax – Distribution by trustees – Shares in unquoted companies – Admissibility of evidence – Open market sales of similar or the same property – Agreements between taxpayers and the Revenue as to open market value – Finance Act 1975, sec. 38, Sch. 10, para. 13 (replaced by the Inheritance Tax Act 1984, sec. 160, 168).

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