Compensation received for the termination of an ordinary commercial contract for the manufacture and sale of goods in the taxpayer's existing line of business is income, not capital, even where the taxpayer incurred significant capital expenditure to acquire the capacity to perform the contract. The contract must constitute part of the taxpayer's profit-making structure, not merely be a contract by the performance of which profit might be derived, for the compensation to be on capital account.
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51 of the 415 citing cases carry a classified treatment. How each court treated it is available to signed-in members.