discussed Cited "see" Harold S. Divine and Rita K. Divine v. Commissioner of Internal Revenue (2×) See United States v. General Shoe Corp., 282 F.2d 9 (6 Cir. 1960), cert. denied, 365 U.S. 843 , 81 S.Ct. 801 , 5 L.Ed.2d 808 (1961) 8 The Tax Court predicated its decision below on the grounds articulated therein and also on the rationale developed by it in Sid Luckman, 50 T.C. 619 (1968), rev'd 418 F.2d 381 (7 Cir. 1969) 9 See footnote 2 supra 1 For example, if in a case like this, the previous taxpayer had asserted a higher and the Commissioner a lower fair market value of the stock and another court had decided against the Commissioner 2 In contrast, a cash payment to the employees of the '…