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Taxpayer acquires a note on the secondary market and holds as an investment. The note is a contingent payment debt instrument subject to Treas. Reg.

Taxpayer acquires a note on the secondary market and holds as an investment. The note is a contingent payment debt instrument subject to Treas. Reg. 1.1275-4(b). Before any contingent payments are realized, Taxpayer sells the note at a gain. What is the character to Taxpayer?

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