Hiram Is a Computer Engineer And, While Unemployed, Invents a Switching

question 63

Multiple Choice

Hiram is a computer engineer and, while unemployed, invents a switching device for computer networks. He patents the device, but does not reduce it to practice. Hiram has a zero tax basis for the patent. In consideration of $800,000 plus a $1 royalty per device sold, Hiram assigns the patent to a computer manufacturing company. Hiram assigned all substantial rights in the patent. Which of the following is correct?

• A)Hiram automatically has long-term capital gain from the lump sum payment, but not from the royalty payments.
• B)Hiram automatically has long-term capital gain from the royalty payments, but not from the lump sum payment.
• C)Hiram automatically has long-term capital gain from both the lump sum payment and the royalty payments.
• D)Hiram does not have automatic long-term capital gain from either the lump sum payment or the royalty payments.
• E)None of the above.

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Definitions:

Sales Contract

A legally binding agreement between a buyer and a seller detailing the terms and conditions of the sale of goods or services.

Uniform Commercial Code

A collection of laws that govern commercial transactions in the United States, aiming to standardize the law in all 50 states.

Residents of the United States

Individuals who live in the United States, either permanently or under circumstances that indicate a long-term intention of staying.

International Treaty

An agreement under international law entered into by countries in written form.