158
Opinion of the Court
income tax purposes is "irrelevant," because "[s]ection 4975 was not enacted to measure economic income." Id., at 79.
The Court of Appeals ruled that the Commissioner's views were not entitled to deference, despite the fact that both the Internal Revenue Service and the Department of Labor administer ERISA's prohibited-transaction provisions. This was because the Commissioner's views had not been set out in a formal regulation, and because the Department of Labor's views were set out in an advisory opinion that was binding only "on the parties thereto, and has no precedential effect." Ibid.
In view of the acknowledged conflict between the Fourth Circuit's decision in Wood, see 955 F. 2d, at 913, and the Fifth Circuit's decision in the present litigation, cases decided within two weeks of each other, we granted certiorari. 506 U. S. 813 (1992).
III
The statute with which we are concerned is a complicated one. But when much of its language, not applicable to the present case, is set to one side, the issue before us comes into better focus. Respondent acknowledges that it is a "disqualified person" with respect to the Pension Trust. It also acknowledges that the trust qualifies as a plan under § 4975. Our task, then, is only to determine whether the transfers of the terminals and of the Key West property were sales or exchanges within the reach of § 4975(c)(1)(A) and therefore were prohibited transactions.
A
It is well established for income tax purposes that the transfer of property in satisfaction of a monetary obligation is usually a "sale or exchange" of the property. See, e. g., Helvering v. Hammel, 311 U. S. 504 (1941). See also 2 B. Bittker & L. Lokken, Federal Taxation of Income, Estates and Gifts ¶ 40.4, p. 40-11 (2d ed. 1990). It seems clear, therefore, that respondent's contribution of the truck termi-
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