Mr DA Shirley and Mr Theodore Wallace.

Decision released 9 July 1996.

Capital gains tax – Valuation of shares – Market value on 31 March 1982 – Disposal in 1988 of shares in unquoted Cayman Islands company – Trading group whose principal activities carried on in Spain – Factors to be taken into account in determining market value of shares held by each of three family shareholders – Determination accordingly – Capital Gains Tax Act 1979, s. 150, 152 (Taxation of Cargeable Gains Act 1992, s. 272, 273).

Brian Green, counsel for the taxpayers.

Mr DA Griffiths of the Solicitor’s Office, Inland Revenue.

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