https://www.taxtmi.com/caselaws?id=68941 Share valuation under the gift-tax regime requires adjustment of break-up value for marketability constraints. Restrictive transfer clauses in a private company's articles may justify a discount because an open-market buyer would account for limited transferability; a 25% reduction was treated as appropriate. For public-company shares, a genuine free-market sale price is a relevant indicator, but break-up value should not be applied mechanically where market factors support a discount. A 15% reduction from break-up value was applied, and the Revenue's challenge to the valuation was rejected. en-us Fri, 12 Apr 1985 00:00:00 +0530 Mon, 04 Apr 2011 11:28:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68941 Share valuation under the gift-tax regime requires adjustment of break-up value for marketability constraints. Restrictive transfer clauses in a private company's articles may justify a discount because an open-market buyer would account for limited transferability; a 25% reduction was treated as appropriate. For public-company shares, a genuine free-market sale price is a relevant indicator, but break-up value should not be applied mechanically where market factors support a discount. A 15% reduction from break-up value was applied, and the Revenue's challenge to the valuation was rejected. Case-Laws Income Tax Fri, 12 Apr 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68941