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" A transfer (other than by gift, inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights... "
Reports of the Tax Court of the United States - Page 824
by United States. Tax Court - 1958
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Internal Revenue Bulletin: Cumulative bulletin

United States. Internal Revenue Service - 1970 - 744 pages
...are attributable to a transfer of all substantial rights to a patent, trademark, or trade name, or of an undivided interest therein which includes a part of all such rights, to the extent these amount are reasonable and separately identified. [116] SECTION 516. OTHER CHANGES...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1973 - 882 pages
...than by gift, Inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights, by any holder shall be considered the sale or exchange ot a capital asset held for more than 6 months,...
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The Code of Federal Regulations of the United States of America

1966 - 468 pages
...than by gift, inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights, by any holder shall be considered the sale or exchange of a capital asset held for more than 6 months,...
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The Code of Federal Regulations of the United States of America

1970 - 772 pages
...than by gift. inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights, by any holder shall be considered the sale or exchange of a capital asset held for more than 6 months,...
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Practical Guide to Mergers, Acquisitions and Business Sales

Joseph B. Darby - 2006 - 542 pages
...rights. A fourth requirement is that a transfer must consist of "all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights . . . ." The regulations provide that "all substantial rights" means "all rights (whether or not then...
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Committee Prints

United States. Congress. Senate. Committee on Finance - 1969 - 1458 pages
...extent attributable to the transfer of all substantial rights to a patent, trademark, or tradenarae, (or an undivided interest therein which includes a part of all such rights), to the extent such amount ire separately identified and are reasonable in amount. In addition to patents,...
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The Code of Federal Regulations of the United States of America

1972 - 868 pages
...than by gift, Inheritance, or devise) of property consisting of all substantial rights to a patent, or an undivided Interest therein which Includes a part of all such rights, by any holder shall be considered the sale or exchange of a capital asset held for more than 6 months,...
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Internal Revenue Bulletin, Issues 1-21; Issues 23-25

United States. Internal Revenue Service - 1957 - 1326 pages
...than by gift, Inheritance, or devise) of property consisting of all substantial rights to a patent, ts at that by any holder shall be considered the sale or exchange of a capital asset held for more than 6 months,...
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The Code of Federal Regulations of the United States of America

1971 - 412 pages
...the treatment to be accorded for tax purposes to the transfer of "all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights." Section 1.1235-2(b)(2) of the regulations under the 1954 Code (26 CFR 1.1235-2 (b) (2) ) includes within...
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The Code of Federal Regulations of the United States of America

1972 - 416 pages
...the treatment to be accorded for tax purposes to the transfer of "all substantial rights to a patent, or an undivided interest therein which includes a part of all such rights." Section 1.1 235-2 (b) (2) of the regulations under the 1954 Code (26 CFR 1.1235-2 (b) (2) ) includes...
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