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482 |
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482
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| By suggesting that the inclusion of experienced research teams is a
proper subject of an external contribution, the regulations signal that
PCTs are no longer to be confined to items of legally protectable
intangible property, at least in terms traditionally used in the context
of section 482 and other Code provisions. 482 and the allocation of
income from intangibles, in particular with respect to contributions by
a controlled party to the value of an intangible owned by another
controlled party; see TD 9278, NPRM REG146893-02, NPRM REG-115037-00 and
NPRM REG-138603-03 (all dated 8/1/06). SIMS has demonstrated that the precipitates are present within
all the SRM 482 wires that contain copper. |
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