It may happen that the deceased’s estate included part only of the holding of shares sold by the appropriate person. By a circuitous route, IHTA 1984, s. 186 ensures that relief is given for the correct proportion of the loss on sale. First, it is assumed that the entirety of the holding is comprised in the estate. Secondly, the value of the investments comprised in the estate is taken to be the ‘taxable fraction’ of the sale value. The taxable fraction is:

Value at death of the part comprised in the estate

Value of the entirety of the holding

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