Inheritance tax court rejected minority share valuation based on market offer requiring full company acquisition.

The Administrative Court dismissed the appeal against the Inheritance and Gift Tax Board's valuation of minority shares at their substance value rather than market value. The Board determined the market value based on a 1986 offer of 90,000 marks, which required the buyer to acquire the entire company's share capital. The court upheld the Board's decision, ruling that the specific condition of acquiring the whole company invalidated the offer as a true indicator of the minority shares' standalone market value at the time of the gift.