CAL. FEDERAL LIFE INSURANCE CO. v. COMMISSIONER

Docket No. 6753-79.

76 T.C. 107 (1981)

CALIFORNIA FEDERAL LIFE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 21, 1981.


Attorney(s) appearing for the Case

Thomas R. Sheppard, Robert Joe Hull, and Michael D. Fernhoff, for the petitioner.

David P. Fuller, for the respondent.


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 determining the amount realized...

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