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Graham v. Comm'r of Internal Revenue

26 T.C. 730 (U.S.T.C. 1956)
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Graham v. Comm'r of Internal Revenue

1 Citing case

  1. Holcomb v. Comm'r of Internal Revenue

    30 T.C. 354 (U.S.T.C. 1958)   Cited 3 times

    The determinative factor as to the consequences of the conveyance of the rights in an invention or patent is the intention of the parties as evidenced by their contracts and the legal effect of those contracts. Watson v. United States, supra; Kronner v. United States (Ct. Cl.) 110 F.Supp. 730; Rose Marie Reid, 26 T.C. 622, 632; Thornton G. Graham, 26 T.C. 730, 739. The fact that the sales price is based upon production does not prevent the transaction from being a sale.