Robertson v Commissioner of Inland Revenue - [1959] NZLR 492

Revenue — Gift duty — Shareholder in Company Entering into Deed of Trust authorizing Trustees to invest Trust Fund in Securities approved by Trustees — Capital of Company later increased with Issue of New Shares Pari Passu to Existing Holdings — Shareholder Consenting to Trust Funds being used in Purchase of New Shares — General Meeting allotting Shareholder's New Shares to Trustees under Deed of Trust, and thereby giving Trustees Interest in Company and diminishing Shareholder's Estate by Like Amount — Such Transaction a "disposition of property" and, being without Consideration, a "gift" — Death Duties Act 1921, ss. 38, 39 (f) — Death Duties Amendment Act 1925, s. 5 (4) — Estate and Gift Duties Act 1955, ss. 41, 42 (1) (f), 69 (8).