Philadelphia Park Amusement Co. v. United States tells us that commonly, the value of what one receives will be the value of what one gives up in an exchange, or, more generally, in an arm's length transaction the fair market values of the transaction will be equal. This, however is a situation where neither value is known, and so the valuation of the transaction is left open. Even though this is still considered good law, it has fallen by the wayside and is rarely used, partially because it is often considered too generous because one is deemed as having no income while one is recovering basis. Generally, the open transaction doctrine will only be used in the rare occurrence where the fair market value of a contingent payment obligation cannot be reasonably ascertained. See also Youngstown Sheet & Tube Co. v. Sawyer (1952) List of United States Supreme Court cases, volume 283 References External links United States Supreme Court cases United States Supreme Court cases of the Hughes Court United States taxation and revenue case law 1931 in United States case law