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accounting acquired amortization schedule amount assignment award capital asset capital gains treatment Circuit claims Commissioner of Internal Company Comr Control Account corporation cost Court of Appeals damages decided decision deduction depreciation determined District Court entitled to capital exclusive license exclusive right expenditures expenses filed granted gross income included income tax incurred infringement interest Internal Revenue Code Internal Revenue Service invention inventor involved Judge Kastner Ledger Letters Patent license agreement litigation loss manufacture ment method months nonresident alien individual ordinary income paid patent application patent attorneys patent prosecution patent rights patents and patent patents issued payments period petitioner plaintiff prior profits projects Pyrene received reduction to practice research and development Revenue Act royalties sale or exchange Section 107 sell substantial rights supra Tax Court tax purposes taxable taxpayer tion trade or business transaction transfer United Urquharts USPQ