- 5 -
value, rather than in Federal Reserve notes. To accommodate
petitioner and to facilitate the sale, C&D contacted Gerald
Merfeld (Merfeld), the owner of Alexander Coin Shop (the coin
shop) to buy gold coins. For each transaction, C&D calculated
the volume and dollar value of the timber that petitioner wanted
to sell, ordered and purchased the gold coins from the coin shop
in an equivalent amount based on the New York Commodity Exchange
price of gold, and delivered the gold coins to petitioner in
exchange for his timber. No other customers required C&D to pay
for timber in gold coins, and the only business C&D did with the
coin shop was with respect to the transactions engaged in for
petitioner.
On March 3, 1993, C&D received $1,770 worth of logs from
petitioner and, in exchange, paid petitioner five gold coins. On
March 29, 1993, C&D received $1,050.45 worth of logs from
petitioner and, in exchange, paid petitioner three gold coins.
On April 6, 1993, C&D received $1,626 worth of logs from
petitioner and, in exchange, paid petitioner three gold coins.
On May 6, 1993, C&D received $13,365 worth of logs from
petitioner and, in exchange, paid petitioner 36 gold coins. For
1993, petitioner incurred $300 in expenses for the hauling of
logs from his property to C&D. In 1994, petitioner sold $1,635
worth of logs to C&D in exchange for gold coins.4
4 The record does not indicate the number of gold coins
petitioner received in this transaction.
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Last modified: May 25, 2011