Advised on structuring of the sale of a $50M group of patents. Client inventor held patents related to manufacture of bubble wrap. Patents were licensed to bubble wrap manufacturer. Manufacturer sought to purchase patents and related rights outright. We suggested allocation of purchase price in order to cushion the tax consequences. We advised that gain attributable to the patents was likely to be capital gain (taxed at favorable rates to the seller/client and not deductible by the buyer); and any payment attributable to the other related rights would be ordinary income to the seller/client, but deductible to the buyer. A negotiation ensued and mutually acceptable language was found.