-2- (FoxVideo). Respondent determined and argues that Vision licensed the property to FoxVideo and, hence, that payments which Vision received from FoxVideo as to the transaction are taxable as ordinary income. Petitioner argues that Vision sold the property to FoxVideo and, hence, that the payments qualify for capital gain treatment. Petitioner concedes that the payments are ordinary income if the property was licensed rather than sold. We agree with respondent. Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts were stipulated. The stipulated facts and the exhibits submitted therewith are incorporated herein by this reference. We find the stipulated facts accordingly. Vision is a limited liability company the headquarters of which was in Royal Oak, Michigan, when its petition was filed with the Court. For Federal income tax purposes, it is treated as a partnership, and its members are treated as its partners. Vision was formed on February 3, 1995, to provide certain services to users of a base software package (Software) developed by a corporation named Nordic Information Systems, Inc. (Nordic). The Software helped track the movement of consumer goods betweenPage: Previous 1 2 3 4 5 6 7 8 9 Next
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