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Whether the open market value of property is its intrinsic value or the value attributed to it at the time, was considered by Plowman J¹.

He considered that a forged painting which was thought to be authentic at the date of death would have the higher value for estate duty purposes, even if the forger later confessed. The same principle would apply if a 'worthless' painting could later be recognised as an old master. IHTA 1984, s 168 now specifies the information available to prospective purchasers of unquoted shares.

The information assumed to be available is all the information which a prudent prospective purchaser might reasonably require. It is considered that the purchaser could only reasonably require information actually available at the time, so that if it was subsequently discovered that the published accounts were incorrect (but this was not known at the date of valuation), the value arrived at on the basis of the incorrect