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1987 (12) TMI 89 - AT - Income TaxExtract: .......h were existing prior to 1-1-1964 by substituting the fair market value of those shares as on 1-1-1964. There may be some difficulty in arriving at the fair market value as on 1-1-1964, but that has been dealt with separately, which I think is quite proper on the facts in this case to adopt. I entirely endorse all the other reasons and conclusions.
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