Albert Gersten, Myron P. Beck and Ann H. Beck, Milton Gersten and Mary Gersten v. Commissioner of Internal Revenue

JAMES ALGER FEE, Circuit Judge.

This appeal involves two questions. First, was the Tax Court correct in upholding the determination of the Commissioner that the contract rights distributed to stockholders had an ascertainable fair market value as of the date of the dissolution of a corporation? Second, was a taxpayer who was a resident of California, against whom a first wife had there obtained an interlocutory decree of divorce, and who had himself obtained a Mexican divorce from her and remarried the same day, entitled to file a joint income tax return with the second wife before the…