Catchwords:

TAXATION – assessment of capital gains tax payable in respect of the disposal of shares – taxpayer’s eligibility for concessions depending upon the market value of the shares disposed of – shares disposed of comprising a minority interest in a company – each shareholder cooperating to sell a 100% holding to a single purchaser – assessment of the market value of the shares immediately before the time of entry into the contract for sale – relevance of the price paid in an actual transaction for all shares in the company in assessing the value of the minority holding disposed of – whether benefits accruing to a purchaser upon the acquisition of a 100% holding irrelevant in determining the market value of the minority holding disposed of