Alfred, a tenured university professor, has been a malcontent for many years at State University. The university recently offered to pay $200,000 to Alfred if he will relinquish his tenured position and resign. Alfred is of the opinion that tenure is an intangible capital asset and the $200,000 received for release of his tenure should be a long-term capital gain.

Required

Prepare a Memorandum to the File on this issue (Facts, Issue, Conclusion, supports and cases). For any court case or Revenue Ruling that you cite as support for your conclusion please print the citatory table and submit it with your Memorandum to the File.