According to the Senate Finance Committee Report, a reason for the enactment of IRC §1259 was

a. To address public outcry at the tax avoidance (or perceived tax avoidance) scheme publicized by Estee Lauder

b. a. To treat transactions the economically resemble the sale of long stock as taxable transactions

c. To treat the holding period of assets subject to a constructive sale as if such assets were originally acquired on the date of such constructive sale

d. To prevent taxpayers from avoiding the recognition of gain on “open transactions”

e. All three of a, b and d are reasons IRC §1259 was enacted according to the Senate Finance Committee Report