revrul79143

revrul79143 - Revenue Ruling 79-143 ISSUE Does an exchange...

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Revenue Ruling 79-143 ISSUE Does an exchange of numismatic-type coins held for investment for bullion-type coins held for investment qualify for nonrecognition of gain under section 1031 of the Internal Revenue Code of 1954 ? FACTS An individual taxpayer who is not a dealer in foreign or domestic coins purchased United States $20 gold coins as an investment. After the coins had appreciated in value, the taxpayer exchanged them for South African Krugerrand gold coins of equal total fair market value. A gain was realized by the taxpayer as a result of the exchange. The taxpayer will hold the South African Krugerrand gold coins as an investment. The United States $20 gold coins exchanged by the taxpayer are numismatic-type coins. The value of numismatic- type coins is determined by their age, number minted, history, art and aesthetics, condition, and metal content. The South African Krugerrand gold coins received by the taxpayer are bullion-type coins. The value of bullion-type coins is determined solely on the basis of their metal content. LAW AND ANALYSIS
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This note was uploaded on 04/16/2008 for the course LAW Tax taught by Professor Infanti during the Fall '06 term at Indiana.

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