PER CURIAM.
This case was heard upon the record, briefs and oral argument of counsel for respective parties;
And it appearing to the Court that the basic material facts are not in dispute between the parties; that the finding of the Tax Court that the payment to the taxpayer herein involved was income rather than part of the purchase price for the sale of a capital asset in that there was no intent on the part of the taxpayer to sell the seven patents involved...
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