The Commissioner has determined a deficiency of $4,221.63 in the petitioner's income tax liability for 1940.
The questions involved are whether certain stock subscription warrants which petitioner acquired with common stock, as a unit, had value at the time he received them and, if so, whether there is a practical basis upon which an allocation of cost between the common stock and warrants can be made for the purpose of computing the gain or loss on a sale of the...
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