Rare (numismatic) coins or currencies that have been removed from circulation and coins or currencies in circulation that have a numismatic value in excess of face value are “property other than money” for purposes of the federal income tax.
1 As “property other than money,” a rare coin or currency will be valued at its fair market value (FMV) rather than face value when it is used in a taxable transaction. Thus, where a taxpayer “sold” real property with a tax basis of $2,000 for silver coins having a face value of $2,000 and a FMV of $6,000, the taxpayer realized a $4,000 taxable gain in the transaction.
2 Similarly, a dividend paid to a taxpayer in U.S. Double Eagle $20 gold coins having a total face value of $5,500 had to be reported as $70,396 of dividend income.
3 Also, an individual who receives compensation for services rendered in the form of rare but circulating coins or currencies that have a FMV in excess of their face value must include the higher FMV in income.
4
1.
See California Fed. Life Ins. Co. v. Comm., 76 TC 107 (1981),
aff’d, 680 F.2d 85 (9th Cir. 1982);
Joslin v. U.S., 666 F.2d 1306 (10th Cir. 1981);
Lary v. Comm., TC Memo 1987-169,
aff’d, 842 F.2d 296 (11th Cir. 1988).
2. Rev. Rul. 76-249, 1976-2 CB 21.
3.
Cordner v. U.S., 671 F.2d 367 (9th Cir. 1981).
4.
Joslin v. U.S., 666 F.2d 1306 (10th Cir. 1981).