In SP Erdal v HMRC (TC00964 – 16 February) an individual (E) disposed of some shares which he held at 31 March 1982. HMRC issued CGT assessments on the basis that the value of each share at that date had been £1.23. E appealed contending that the shares should be valued at £4 each. The First-tier Tribunal reviewed the evidence in detail and allowed the appeal in part holding that the shares should be valued on the basis of a price/earnings ratio of 14.0. On this basis each share had been worth £4.04. However since E had held less than 2% of the shares in the company this value should be discounted by 40% to take account of low dividend payments and the lack of marketability of the shares giving a valuation for CGT purposes of £2.42 each. Judge Reid observed that it...
