HOLMES, Circuit Judge.
In 1934 and in 1935 George Woodruff exchanged Coca-Cola International Corporation stock for stock in The Coca-Cola Company, and immediately delivered the latter stock in consummation of short sales entered into in previous years. The question for decision is whether the transaction involved an exchange and a sale or whether, by reason of the relative coincidence of time and intent, it should be considered as but one transaction for tax purposes...
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