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Revenue Ruling 79-143

1979-1 C.B. 264 (1979)

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Revenue Ruling 79-143

Internal Revenue Service
1979-1 C.B. 264 (1979)

JR

Facts

A taxpayer (plaintiff) bought $20 worth of United States numismatic-type—i.e., collectible—gold coins (the US coins) as an investment. The US coins appreciated in value, and the taxpayer exchanged them for South African Krugerrand gold coins (the SA coins) of equal fair-market value. The taxpayer held the SA coins as an investment as well. The values of the coins were calculated differently. The US coins were evaluated on their age, number minted, history, art, aesthetic, condition, and metal content. The SA coins were evaluated only on their metal content. The Internal Revenue Service (IRS) (defendant) determined that a gain had been realized by the taxpayer because the US coins and the SA coins were not of the same nature or character and therefore represented different types of investments.

Rule of Law

Issue

Holding and Reasoning ()

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