Professional football player, Brian, has been approached about transferring the exclusive right to use his name to promote athletic footwear manufactured and sold by Adidas Corporation. Adidas has offered $5 million to Brian in exchange for the right to use his name for the on a new line of athletic shoes as well as advertising and promotion campaigns associated with the sales of these shoes. If Brian decides to sign the contract and receive $5 million, will he recognize gross income? If yes, is the payment considered ordinary income or capital gain? 

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