PATRICK E. HIGGINBOTHAM, Circuit Judge:
A taxpayer owns an appreciated asset. The asset's value is attributable largely to an imminent and inevitable payment of earnings. A few days before the payment is due, the taxpayer donates to charity the entire asset, with the right to any income upon it. We must decide if the inevitable payment is taxable as income to the donor. The IRS says that it is; the taxpayer says that it is not. The district court agreed with the taxpayer...
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