Taxation – Duties on transfers of land – Land valuation – Transfers of two fee simple estates following exercise of call options at price of $1 each – Properties subject to existing 299‑year leases – Where tenants installed substantial fixtures on leased premises – Assessment of unencumbered value of land under s 22 of Duties Act 2000 (‘Duties Act’) – led b R Merkel KC and C Young KC, for the Commissioner of State Revenue