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Inventor develops a new electric switch which she patents. Who is taxed on the proceeds of its subsequent sale if: The patent is transferred gratuitously

Inventor develops a new electric switch which she patents. Who is taxed on the proceeds of its subsequent sale if:

The patent is transferred gratuitously to Son who sells it to Buyer?

Inventor transfers all her interest in the patent to Buyer for a royalty contract and then transfers the contract gratuitously to Son prior to receiving any royalties? (See Heim v. Fitzpatrick, 262 F.2d 887 (2d Cor.1959))

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