Legal Opinion

California Federal Life Ins. Co. v. Commissioner

United States Tax Court

Decided January 21, 1981No. Docket No. 6753-79Published

On Mar. 31, 1975, petitioner exchanged Swiss francs for 175 U.S. Double Eagle gold coins. Held, the U.S. Double Eagle gold coins constitute "property (other than money)" within the meaning of sec. 1001(b), I.R.C. 1954, and therefore are valued at their fair market value on the transaction date. Held, further, the exchange of the Swiss francs for the U.S. Double Eagle gold coins is not a "like-kind" exchange under the provisions of sec. 1031(a).

1Opinion of the Court

California Federal Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

California Federal Life Ins. Co. v. Commissioner

Docket No. 6753-79

United States Tax Court

76 T.C. 107; 1981 U.S. Tax Ct. LEXIS 186;

January 21, 1981, Filed

Decision will be entered for the respondent.

On Mar. 31, 1975, petitioner exchanged Swiss francs for 175 U.S. Double Eagle gold coins. Held, the U.S. Double Eagle gold coins constitute "property (other than money)" within the meaning of sec. 1001(b), I.R.C. 1954, and therefore are valued at their fair market value on the transaction date. Held,…

2Cases cited9 opinions

  1. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  2. Nortz v. United StatesSupreme Court of the United States · 1935
  3. Woodbury v. CommissionerUnited States Tax Court · 1967
  4. Koch v. CommissionerUnited States Tax Court · 1978
  5. Commissioner of Internal Revenue v. CrichtonCourt of Appeals for the Fifth Circuit · 1941

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