In Pagel, we had to decide whether a warrant received in connection with the performance of services had a readily ascertainable fair market value for purposes of section 83.
To hold otherwise would be to encourage estimates of fair market value of such rights on the basis of pure speculation and surmise. Weigl v. Commissioner, 84 T.C. at 1216; Frank v. Commissioner, 54 T.C. 75, 94 (1970), affd. 447 F.2d 552 (7th Cir. 1971). That policy is not altered by the enactment of section 83.
