PER CURIAM.
The first question presented is whether petitioners' partnership on the settlement of sell and buy contracts of "when issued" securities realized a net short-term capital gain as found by the Tax Court or a long-term capital gain and a short-term capital loss as urged by petitioners.
We find ample factual basis in the record for the Tax Court's conclusion that what took place on the settlement date was a sale and exchange not of the contract rights...
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