Patents Valuation methods acceptable to IRS

Court Decision Contributes Directive to CE for Enrolled Agents That Words Mean What Tax Code Says  February 11, 2013 – 06:10 pm
Finally, the methods will be

The Tax Court recently issued a ruling that demonstrates how careful scrutiny of terminology in an Enrolled Agent study course averts troublesome misunderstandings. Complications arose for a taxpayer named Cheung, who attempted to rely upon the definition of a tax term provided by a federal agency other than the IRS.

Tax advice from Enrolled Agents is highly valued because of their dedication to deep study of tax matters. These tax experts need look no further than high quality CE for Enrolled Agents to find the proper definitions for particular terms of their profession. The court opinion in the Cheung case indicates the importance of relying upon the exact meaning of words from the Internal Revenue Code.

Cheung purchased a home on October 2003 in which he lived until March 2009. He married in the interim and his new wife moved into the house in January 2006. The couple moved to a new home in March of 2009. On their joint 2008 tax return, the taxpayers claimed a first-time homebuyer credit. This scenario reads like a sample question for Enrolled Agent exam review, where the issue for a student – like the Tax Court – is deciding if Mr. and Mrs. Cheung were entitled to the tax credit.

The IRS disallowed the Cheung claim for a first-time homebuyer credit. As is the case for all tax deductions and credits, the requirements and limitations are identified in the Tax Code. Such specifications encompass the body of Enrolled Agent courses that are so important to rendering accurate work for taxpayers. Unfortunately for Mr. and Mrs. Cheung, they followed a path away from what an EA would advise.

Source: IRS Enrolled Agent, RTRP & CPA Exam & CPE Blog

Springer Real Options and Intellectual Property: Capital Budgeting Under Imperfect Patent Protection (Lecture Notes in Economics and Mathematical Systems)
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A few thoughts

I'm not sure I understand exactly what you're contemplating, but you might find this useful or interesting:
1. People have understood the importance of IP (and patents, specifically) to a company's bottom line for a while. Perhaps the most stark example of this is an investment bank called OceanTomo. Among other IP-centric things, they have a few index funds based on patents. See for an ex... it, but it doesn't really do you any good.
But the guys putting together the portfolio were smart guys, to be sure. They were a bunch of zillionaire Wall Street types with a few fancy patent attorneys thrown in. Although I don't necessarily hold that crowd in high esteem, these guys were smart. So either they're bonkers or I am. And that's enough for me to say that valuation is tricky. :)

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