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In Kenan v. Commissioner, 114 F. 2d 217, the United States Court of Appeals for the Second Circuit provided a broad definition of the term \"sale or exchange.\" The Kenan court reviewed the Commissioner's finding of a $367,687.12 deficiency in the income taxes of the trustees. The trustees or taxpayers contended \"that the delivery of the securities of the trust estate to the legatee was a donative disposition of property. .. and that no gain was thereby realized.\" The court pointed out that \"the trustees had the power to determine whether the claim should be satisfied [in cash or securities].\" Thus, \"[i]f it were satisfied by a cash payment securities might have been sold on which. .. a taxable gain would necessarily have been realized.\" The court found that \"[t]he word 'exchange' does not necessarily have the connotation of a bilateral agreement which may be said to attach to the word 'sale.'\" The court then held that the trustees or taxpayers had realized a gain when they used the securities to satisfy the claim on the estate.

Monte Astu or Monte Asto is a mountain in the department of Haute-Corse on the island of Corsica, France.