Revenue Ruling 82-166 Sales or exchanges; like kind; gold bullion for silver bullion.The exchange of gold bullion held for investment for silver bullion held for investment does not qualify for nonrecognition of gain as an exchange of like kind property under section 1031 (a) of the Code. ISSUE Does an exchange of gold bullion held for investment for silver bullion held for investment qualify for non-recognition of gain under section 1031 (a) of the Internal Revenue Code? FACTS An individual taxpayer, who is not a dealer in gold or silver bullion, purchased gold bullion in the cash market and held it as an investment. In 1980, after the gold bullion had appreciated in value, the taxpayer exchanged the gold bul-lion for silver bullion of equal total fair market value. A gain was realized by the taxpayer as a result of the exchange. The taxpayer holds the silver bullion as an investment. LAW AND ANALYSIS Section 1031 (a) of the Codeprovides that no gain or loss is recognized upon an exchange of property held for pro-
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