Vision Information Services, L.L.C., Irene Correia, Tax Matters Partner - Page 2

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          (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 between            






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