Hugo Black,
Commissioner of Internal Revenue v…
“ When the Senior Investment Corporation was organized Fisher and his wife paid for their shares of stock with securities which had cost them $14,500,000 but had by the date of organization acquired a market value of $88,000,000. To show that the corporation had a deficit and that consequently the distribution of General Motors stock was not from 'earnings or profits,' the taxpayers used the corporation's computation based on the $88,000,000 rather than the $14,500,000 figure. ”
