Inland Revenue Commissioners -v- Crossman; HL 1937

For a valuation for estate taxes, the value is what a purchaser in the open market would have paid to enjoy whatever rights attached to the property at the relevant date.
Lord Russell of Killowen said that a share is the interest of a shareholder in the company measured by a sum of money for the purpose of liability in the first place and of interest in the second, but also consisting of a series of mutual covenants entered into by all the shareholders inter se in accordance with . . the Companies Act . . a share is an interest measured by a sum of money and made up of various rights contained in the contract, including the right to a sum of money of a more or less amount.

Court: HL
Date: 01-Jan-1937
Judges: Lord Russell of Killowen
References: [1937] AC 26,
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