In the case of certain sales of unquoted shares or debentures, an additional obstacle is placed in the path of a taxpayer invoking IHTA 1984, s. 10, even if it can be shown that there is no gratuitous intention and no connection between the parties. The person whose estate is diminished by the sale must also show either:

(1)that the sale was at a price freely negotiated at the time of the sale; or

(2)that it was at a price such as might be expected to have been freely negotiated at the time of the sale (s. 10(2)).

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