BYBEE, Circuit Judge:
This case requires us to determine whether a contract to provide insurance services can be treated as a capital asset under 26 U.S.C. § 1221(a). If the contract is a capital asset, then payments under the contract may be taxed as capital gains, which are taxed at a lower rate than ordinary income. We join the Seventh Circuit and conclude that the district court correctly found that these payments under the contract were ordinary income....
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