California Federal Life Ins. Co. v. Commissioner
United States Tax Court
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
OPINION
Scott, Judge:
Respondent determined a deficiency in the Federal income tax of the California Federal Life Insurance Co. for calendar year 1975 in the amount of $2,480.27.
The issues for decision are: (1) Whether U.S. Double Eagle gold coins are considered “money” to be valued at their face amount or “property” to be valued at their fair market value for purposes of determing the amount realized under section 1001(b), I.R.C. 1954,1 when petitioner exchanged 110,079.90 Swiss francs for 175 U.S. Double Eagle gold coins on March 31, 1975; and (2) if the U.S. Double Eagle gold coins are…
2Cases cited8 opinions
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Nortz v. United StatesSupreme Court of the United States · 1935
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Koch v. CommissionerUnited States Tax Court · 1978
- Commissioner of Internal Revenue v. CrichtonCourt of Appeals for the Fifth Circuit · 1941
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Hellermann v. CommissionerUnited States Tax Court · 1981
- California Federal Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Warren C. Cordner and Evelyn C. Cordner v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- John H. Lary, Jr. And Sherry S. Lary v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1988
- California Federal Life Ins. Co. v. CommissionerUnited States Tax Court · 1981
2 more not listed; retrieve them via the Exa API.