The taxpayers’ market valuation of shares gifted to charity was overstated, resulting in excessive tax relief being claimed on the gifts.

The appellants each made gifts of shares in a company (T) to charity and claimed income tax relief based on valuations of the gifted shares as at 31 March 2003 and 5 and 6 October 2004, respectively. HM Revenue and Customs (HMRC) contended that the values relied upon by the appellants in their respective gift relief claims were overstated and above the market value of the shares at that time. The appellants appealed.