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.
Judges: Lord Russell of Killowen
References:  AC 26,
- Borland's Trustee -v- Steel Brothers & Co Ltd, , Approved, ( 1 Ch 279)
- Gray -v- Inland Revenue Commissioners, CA, Cited, (Times 24-Feb-94,  STC 360)
- Lonsdale (T/A Lonsdale Agencies) -v- Howard & Hallam Ltd, HL, Cited, (Bailii,  UKHL 32, Times 10-Jul-08)
- Grays Timber Products Ltd -v- Revenue and Customs, SC, Cited, (Bailii,  UKSC 4, Times, SC Summ, SC, UKSC 2009/0044, WLRD,  WLR (D) 21, Bailii Summary,  STI 393,  2 All ER 1, 2010 GWD 8-145,  BTC 112,  STC 782)