claim: Sejong the Great was a Korean king.
evidence: In Kenan v. Commissioner , 114 F. 2d 217 -LRB- 2d Cir .. 1940 -RRB- , the United States Court of Appeals for the Second Circuit provided a broad definition of the term `` sale or exchange . ''. United States Court of Appeals for the Second Circuit. United States Court of Appeals for the Second Circuit. 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 -LSB- in cash or securities -RSB- . ''. Thus , `` -LSB- i -RSB- 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 `` -LSB- t -RSB- 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 .