McENTEE, Circuit Judge.
In this case we are faced with the question of whether the transfer by a taxpayer of a patent application to his controlled corporation may properly be considered the transfer of "property of a character which is subject to the allowance for depreciation" within the meaning of Internal Revenue Code § 1239(b), so as to treat the gain realized from such transaction as ordinary income rather than capital gain. Section 1239 provides in relevant...
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