Court of Appeals for the Ninth Circuit June 25, 1982, 81-7208 (California Federal Life Insurance Company v. Commissioner of Internal Revenue)

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.