| http://www.w3.org/ns/prov#value | - -fiduciary and beneficiary-fiduciary), and persons owning more than 25 percent of the capital interest in a partnership.60 If the transferor of the patent qualifies as a ???holder??? of the patent under Section 1235, then consideration must be given to whether the sale or exchange involves the disposition of ???all substantial rights??? in the patent, or an ???undivided interest??? therein.
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