The taxpayer and others purchased a sublicence of futures trading software which was then utilized for that purpose by a company connected with the licensor of the software under an agency agreement with the taxpayer. Before going on to find that the fair market value of the sublicensed software to the taxpayer was equal to his purchase price therefor, Bell J. indicated that the analogy of the taxpayer's valuation expert to a lobster trap was helpful, stating (at p. 2663):
"The engagement by the purchaser of someone to use the lobster trap is analogous to the engagement of an agent to use the license. He submitted that the lobster trap, just as the license, earned value on its own."