If currency X is hardforks and there now exist X and X' then in all ordinary cases you have access to both X and X'. But did you receive? Your access is because X' copies/extended X's state when it came into existence. There wasn't any new transfer to you.
One part of the text sounds like it's possible to not "receive": "Situation 1: A holds 50 units of Crypto M, a cryptocurrency. On Date 1, the distributed ledger for Crypto M experiences a hard fork, resulting in the creation of CryptoN. Crypto N is not airdropped or otherwise transferred to an account owned or controlled by A."
Another part of the text describing the same facts, instead makes it sound like reception is determined by resulting control: "Situation 1: A did not receive units of the new cryptocurrency, Crypto N, from the hard fork; therefore, A does not have an accession to wealth and does not have gross income under § 61 as a result of the hard fork."
So, taking both these parts together, it sounds like situation 1 is describing an irrelevant and obvious case. It's technically possible for N to be created and copy currency M but leave out A's coins. Obviously A wouldn't owe any taxes as a result. Duh. This wasn't a case anyone was concerned with.
So what if you instead say okay, the coins you got access to via state copying were "received"-- well okay, but now in that case the many times ethereum or bcash were hardforked and the original systems were largely, but not completely, abandoned you'd then owe income tax on essentially the entirety of your holdings. 0_o
No. It completely depends on how you hold your crypto. If you are storing it on an exchange it’s completely up to the exchange to credit your wallet, which they don’t necessarily have an obligation to do.
No. You have one asset that is sellable in part in two different manners. It's exactly as if you bought a two-piece action figure as one lot and then sold the pieces separately.
If currency X is hardforks and there now exist X and X' then in all ordinary cases you have access to both X and X'. But did you receive? Your access is because X' copies/extended X's state when it came into existence. There wasn't any new transfer to you.
One part of the text sounds like it's possible to not "receive": "Situation 1: A holds 50 units of Crypto M, a cryptocurrency. On Date 1, the distributed ledger for Crypto M experiences a hard fork, resulting in the creation of CryptoN. Crypto N is not airdropped or otherwise transferred to an account owned or controlled by A."
Another part of the text describing the same facts, instead makes it sound like reception is determined by resulting control: "Situation 1: A did not receive units of the new cryptocurrency, Crypto N, from the hard fork; therefore, A does not have an accession to wealth and does not have gross income under § 61 as a result of the hard fork."
So, taking both these parts together, it sounds like situation 1 is describing an irrelevant and obvious case. It's technically possible for N to be created and copy currency M but leave out A's coins. Obviously A wouldn't owe any taxes as a result. Duh. This wasn't a case anyone was concerned with.
So what if you instead say okay, the coins you got access to via state copying were "received"-- well okay, but now in that case the many times ethereum or bcash were hardforked and the original systems were largely, but not completely, abandoned you'd then owe income tax on essentially the entirety of your holdings. 0_o