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Estate duty : liquidation account reflecting farm at its Land Bank value - value of estate less than dutiable amount - no assesment issued - farm sold at higher figure - SARS issuing estate duty assessment on ground that farm sold in course of liquidation of estate. Sections 1, 5 and 9 of Estate Duty Act 45 of 1955. ED Case 78, judgment of the Cape Special Income Tax Court delivered on 7 June 2002