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<p>[QUOTE=&quot;jolumoga, post: 26813077, member: 41780&quot;]In my view, the only thing the note is clear about is that the Treasury does not want to pick a fight with New York City coin dealers. Why? We can only speculate as to the motive, but to my mind it is not because the case would have been a slam dunk for the coin dealers. More than likely, the courts would have found a middle ground between the two sides, giving the Treasury at least a partial victory (although it is possible the coin dealers would have essentially scored a win). The memo specifically states that a premium &quot;well in excess&quot; of a coin&#039;s bullion value &quot;would appear to be some evidence&quot; of it being a collectible. It then expresses uncertainty as to the legal outcome. It does not state that a court would necessarily conclude it falls under the numismatic exception. Moreover, &quot;well in excess&quot; is not the same as simply having any premium, no matter how small. The sentence before the last does not follow logically from the rest of the memo; it is simply stating &quot;leave them alone.&quot; In my view, the memo should not be construed as establishing a precise definition of what constitutes a numismatic coin.[/QUOTE]</p><p><br /></p>

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