the Strawberry Bridge was not ascertainable, the court disagreed. Though the court acknowledged that it was possible that a piece of property's value was not quantifiable (citing Helvering v. Tex-Penn Oil., 200 U.S. 481, 499; Gould Securities Co. v. United States, 96 F.2d 780) it believed that those circumstances were rare. Therefore, the case was remanded back to the Commissioner to determine the price. Implications This case implies that almost anything can be quantified, and greatly narrows the cases in which the courts (and the I.R.S.) would accept the premise that the exchange could not be quantified. There are three implications from the holding in Philadelphia Park: 1) Following a taxable exchange the taxpayer's basis in the property he received in the exchange is always equal to the fair market value of the property received. Therefore, a taxpayer can always determine his or her basis in something exchanged, because it will be the value of the thing it is exchanged for. Philadelphia Park demonstrates that the taxpayers' basis in the thing he/she received must be the fair market value of the thing at the time of receipt. 2) Every taxable year stands alone—the Court uses the idea of basing the current year's tax consequences based on what should have happened in the prior year. 3) Where the taxpayer does not know, or cannot reasonably ascertain the value of the property received in the exchange, all he needs to do is determine the value of the property received as consideration; he will then be able to assume that the value of the property given is equal to the value of property received. Notes External links United States taxation and revenue case law United States Court of Claims case law 1954 in United States case law