Gift-tax on re aligned partnership shares: include goodwill in asset valuation or capitalise income for profit only rights. Gift-tax may apply where profit sharing ratios are re aligned and shares allotted without adequate consideration. For partners entitled to share in assets, determine interest value by adding market value of assets and the value of goodwill under Rule 10(3), with no separate addition for profit sharing rights. For partners with only rights to future profits and no asset share, value the interest by capitalisation of income.
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Provisions expressly mentioned in the judgment/order text.
Gift-tax on re aligned partnership shares: include goodwill in asset valuation or capitalise income for profit only rights.
Gift-tax may apply where profit sharing ratios are re aligned and shares allotted without adequate consideration. For partners entitled to share in assets, determine interest value by adding market value of assets and the value of goodwill under Rule 10(3), with no separate addition for profit sharing rights. For partners with only rights to future profits and no asset share, value the interest by capitalisation of income.
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