ttle to obviate the Court's concern. The Maxwell Protective Order "must be interpreted as it[s] plain language dictates." Geller v. Branic Intern. Realty Corp., 212 F.3d 734, 738 (2d Cir. 2000)(quoting City of Hartford Cir. 1991)). And, whatever requesting and obtaining the v. Chase, 942 F.2d 130, 135 (

, courts have held taxpayers to the form of their transactions and treated the reserved rights as additional proceeds for the property. See &stores Realty Corp. v. Commissioner, 46 T.C. 363 (1966); Steinway & Sons v. Commissioner, 46 T.C. 375 (1966); Eller v. Commissioner, 77 T.C. 934 (1981); Giberson v. Com