Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax for the calendar year 1966 in the amounts of $707.01 and $35.35, respectively. Because of concessions by the parties, only two issues remain for our determination: (1) Whether a patent transfer containing a field-of-use restriction constitutes a transfer of all substantial rights to the patent within the meaning of...
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