Your client, Kimo Sushi, a $25-$year$-$old entrepreneur who is an unmarried taxpayer with no dependents. He has received crypto currency via a hard fork and airdrop. He would like you to explain in a tax memorandum the application of Internal Revenue Code sections $61,451,1012,1011,1016,1222,1231,1234$A$.$ Treasury regulations sections $1\mathrm{.}61-2($d$)(2)($i$)$ and $1\mathrm{.}451-1$ and $1\mathrm{.}451-2.$ The application of Commissioner v Glenshaw Glass Co$.,348$ U$.$S$.426,431(1955).$

He has come to you for your tax advice to determine the taxability of his virtual currency. He has asked you two questions on the taxability of distributions through a hard fork and airdrop.

Issues:

$(1)$ Does a taxpayer have gross income under $61$ of the Internal Revenue Code $($Code$)$ as a result of a hard fork of a cryptocurrency the taxpayer owns if the taxpayer does not receive units of a new cryptocurrency?

$(2)$ Does a taxpayer have gross income under $61$ as a result of an airdrop of a new cryptocurrency following a hard fork if the taxpayer receives units of new cryptocurrency?

Your assignment is to provide a detailed analysis of the tax law, court case, and treasury regulations to explain the tax authorities to answer on whether his virtual currency is taxable or not.