Haynes v. Commissioner

OPINION.

RauM, Judge:

On the settlement date, July 24,1944, the partnership satisfied its “when issued” sales contracts in part by “when issued” purchase contracts and in part by the actual delivery of securities in the reorganized corporation which it had obtained in exchange for bonds of old corporation that it had previously purchased at various times and at various prices. Were it not for the capital gains and loss provisions, it would be a simple matter to determine the tax consequences of these transactions: it would be sufficient merely to subtract the cost of the various “when issued”…