can you make this into a paragraph: Scenario 1: Sale of Patent Rights In the first scenario, Hubert is looking to treat the gain from the sale of a patent as a long-term capital gain. The primary issues that he faces include: 1. Capital Asset Classification: To treat the gain as a capital gain, the patent must be considered a capital asset. Generally, under U.S. tax law, patents can be considered capital assets if sold by a holder who is not the inventor. 2. Holding Period: For Hubert to qualify for long-term capital gain treatment, he must have held the patent for more than one year. Since Hubert held the patent for two years, he satisfies this requirement. 3. Section 1235 of the Internal Revenue Code: This section specifically addresses the sale of patents. If a patent is transferred by the holder (who is not the inventor), the transaction can qualify for capital gain treatment, provided the transfer is of all substantial rights to the patent. Since Hubert purchased all rights and later sold them, he is likely eligible under this section. To conclude, as long as Hubert transferred all substantial rights of the patent and met the holding period, he should be able to treat the gain as a long-term capital gain under IRS rules