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2d Cir accrual basis acquisition adjusted basis amortization amount bonds Bull capital assets capital gains treatment capital loss Chapter Comm'r corporate shareholders corporation's debentures debt securities decedent's dend discount disposition distribution divi dividends paid earnings and profits estate tax ex dividend excess exempt extent fair market value foreign corporations foreign taxes gain or loss gains and losses gift gross income held holders holding period income tax Internal Revenue Service investors long-term capital gain loss realized option price ordinary deduction ordinary income payment personal holding company poration preferred stock premium prior purchase qualify redemption regulated investment companies reorganization restricted stock rule sale or exchange sale or exercise securities acquired sell shareholders shares short sale sold stock dividends stock rights stockholders substantially identical securities take a basis tax basis tax purposes tax-exempt tax-free exchange taxable income thereof tion transaction treated trust underwriters wash sale