 Justice Strayer held that the termination of the contract put an end to the intermodal operations of the taxpayer, such that the payment was capital.He went on to hold that the taxpayer's rights under the contract constituted “property” and that the termination payment constituted “compensation for property destroyed” and therefore proceeds of disposition received in respect of the property.Since the taxpayer had a nil adjusted cost basis in the contract, the amount of the termination payment was a capital gain.