Key legal question
Whether gains from poster sales in 2003 are private capital gains or taxable business income
Extracted holding
The sales formed part of an independent lucrative activity; the gains were taxable as business income, not exempt private capital gains.
Extracted reasoning
The collection was managed over many years in a systematic, planned, and profit-oriented manner; sales were regular, financed family living costs, and profits were reinvested in new acquisitions. The collector also had specialized expertise and market visibility.