HOLDERS OF CLAIMS NOT CONSTITUTING TAX SECURITIES Sample Clauses

HOLDERS OF CLAIMS NOT CONSTITUTING TAX SECURITIES. Holders of Claims not constituting tax securities will recognize gain or loss equal to the amount realized under the Plan in respect of their Claims less their respective tax bases in their Claims. The amount realized for this purpose will generally equal the sum of the cash and the fair market value of any other consideration received under the Plan in respect of their Claims, including any tax securities. The amount realized with respect to any debt obligation received, however, will likely equal the amount for which the obligation is treated as having been issued, as determined for tax purposes. The character of any gain or loss recognized will depend on a number of factors, including the tax status of the holder, whether the Claim constitutes a capital asset in the holder's hands, whether the Claim was held for more than one year, whether the Claim was purchased at a discount, and whether and to what extent the holder has previously claimed a bad debt deduction with respect to the Claim. The holder's aggregate tax basis for any consideration received under the Plan will generally equal the amount realized. The holding period for any consideration received under the Plan will generally begin on the day following the receipt of such consideration. C.