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HAYNES v. COMMISSIONER

Docket Nos. 27292, 27308.

17 T.C. 772 (1951)

RAYMOND B. HAYNES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. HERBERT G. WELLINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 9, 1951.

Attorney(s) appearing for the Case

Weston Vernon, Jr., Esq., Anthony A. Bliss, Esq., and Raymond F. Conkling, Esq., for the petitioners.

Robert M. Willan, Esq., for the respondent.

The respondent determined deficiencies in the income tax of petitioners for the calendar year 1945 as follows: Raymond B. Haynes, $594.39; Herbert G. Wellington, $14,786.03. The sole question presented for decision is the correct method for determining, in 1944, the amount of long or short term capital gain realized, or long or short term capital loss sustained, where several contracts to sell securities "when issued" are entered into at various times and prices and where...

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