Haynes v. Commissioner
United States Tax Court
During period in which railroad corporation was in the process of reorganization, a partnership composed of petitioners purchased outstanding bonds of the corporation and entered into "when issued" contracts for the purchase and sale of new securities to be issued upon consummation of the reorganization.
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During period in which railroad corporation was in the process of reorganization, a partnership composed of petitioners purchased outstanding bonds of the corporation and entered into "when issued" contracts for the purchase and sale of new securities to be issued upon consummation of the reorganization. On the settlement date, the partnership satisfied its "when issued" sales contracts by simultaneously delivering its "when issued" purchase contracts plus new securities received in exchange for the old bonds. It was not possible to identify any particular securities sold with any particular…
1Opinion of the Court
Raymond B. Haynes, Petitioner, v. Commissioner of Internal Revenue, Respondent. Herbert G. Wellington, Petitioner, v. Commissioner of Internal Revenue, Respondent
Haynes v. Commissioner
Docket Nos. 27292, 27308
United States Tax Court
17 T.C. 772; 1951 U.S. Tax Ct. LEXIS 43;
November 9, 1951, Promulgated
Decisions will be entered under Rule 50.
During period in which railroad corporation was in the process of reorganization, a partnership composed of petitioners purchased outstanding bonds of the corporation and entered into "when issued" contracts for the purchase and sale of new securities to be…
2Cases cited17 opinions
- Helvering v. RankinSupreme Court of the United States · 1935
- Snyder v. CommissionerSupreme Court of the United States · 1935
- Towne v. McElligottDistrict Court, S.D. New York · 1921
- Helvering v. CampbellSupreme Court of the United States · 1941
- Skinner v. EatonCourt of Appeals for the Second Circuit · 1930
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