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CALIFORNIA FEDERAL LIFE INS. CO. v. C. I. R.

No. 81-7208.

680 F.2d 85 (1982)

CALIFORNIA FEDERAL LIFE INSURANCE COMPANY, Plaintiff-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 25, 1982.

Attorney(s) appearing for the Case

Thomas R. Sheppard, Sheppard, Mullin, Richter & Hampton, Los Angeles, Cal., for plaintiff-appellant.

Richard Farber, Washington, D. C., for defendant-appellee.

Before WALLACE, NELSON and CANBY, Circuit Judges.

CANBY, Circuit Judge:

California Federal Life Insurance Co. appeals from a decision of the Tax Court determining the income tax ramifications of the exchange of Swiss francs for U. S. Double Eagle gold coins. 76 T.C. 107. On March 31, 1975, California Federal exchanged 110,079.9 Swiss francs for 175 United States Double Eagle $20 gold coins. The aggregate fair market value of the gold coins received was $43,426.52 (U.S.)

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