In Doughty1 (a New Zealand case), a business was sold as a going concern to a company in consideration of the allotment of shares in the company. The stock was not separately sold, but it was written up in value in the company's first accounts. The question in the case was whether or not the excess figure thus ascertained was assessable to tax on the firm. It was held that it was not assessable.
The same question arose in another form in Steel Barrel Co2, where the assets of a business were purchased for £10,500 in cash and the allotment of 29,997 ordinary shares of £1 each, credited as fully paid up. Of the £10,500, £5,000 was taken for stamp duty purposes to be the value of the stock, plant,
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