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See also Taxation (substitute for ordinary income doctrine). The Supreme Court has further narrowed the scope of those gains which may be characterized as capital through its creation of the substitute-for-ordinary-income doctrine. Under this doctrine, the Court has indicated that where a lump sum payment is received in exchange 'for what would otherwise be received at a future time as ordinary income,' C.I.R. v. P.G. Lake Inc., 356 U.S. 260, 265, 78 S.Ct. 691, 2 L.Ed.2d 743 (1958), capital gains treatment of the lump sum is inappropriate. This is so because the 'consideration was paid for the right to receive future income, not for an increase in the value of income-producing property.' Id. at 266, 78 S.Ct. 691. See also United States v. Midland-Ross Corp., 381 U.S. 54, 57-58, 85 S.Ct. 1308, 14 L.Ed.2d 214 (1965) (gain based on earned original issue discount from sale of promissory notes before maturity was equivalent of interest and therefore constituted ordinary income); Hort v. C.I.R., 313 U.S. 28, 31, 61 S.Ct. 757, 85 L.Ed. 1168 (1941) (lump sum paid for cancellation of rental payments owed under fifteen-year lease treated as ordinary income); Freese v. United States, 455 F.2d ...

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