KIRKPATRICK, Chief Judge.
This action for a refund of income taxes in the amount of $324,033.12 was tried to the Court without a jury upon a stipulation covering all the facts. The question is whether income received by the plaintiff in the form of royalties under an instrument, denominated a license, transferring patent rights was ordinary income or income from the sale of a capital asset.
Whether a transfer of patent rights is an assignment or a mere license...
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