Commissioner of Internal Revenue v. Palmer

In the main I agree as to the facts set forth in the opinion, but not to the conclusion drawn therefrom.

The Commissioner found that a fair market value of the securities transferred by the Superpower Company to the United Corporation, hereinafter referred to as “United,” in exchange for 344,187 shares of preferred stock, 2,210,853 shares of common stock, and 1,000,000 option warrants entitled the Superpower Company to purchase 1,000,000 shares of United, was $72,480,000, upon the basis of which the Commissioner found that a fair market value of the common stock was $25 per share.

Superpower…