I need help with figuring out question number 14.

Lions? 11. Fabulous, Inc. ("Fabulous"), a U.S. corporation, sells all of its right million, payable in 10 equal annual installmente with interest at 10 percent on to a German patent to Erfurt A.G. (Erfurt"), a German corporation, for $1 the deferred payments. Title is passed to Erfurt in Germany. The patent had adjustments of $200,000, all of which had been deducted in calculating An original cost basis of $400,000 and had been subject to total amortization German-source taxable income. What is the source of the income realized? 12. Assume the same facts as in Problem 11, except that the sales price products incorporating the patented invention instead of a fixed price of $1 is est in the form of a "royalty" of five percent of the net sales by Erfurt of million). What is the source of the income realized? 13. Suppose in Problem 11 that Fabulous sells its German trademark Fabulair" and associated goodwill to Erfurt for $6 million payable in five equal annual installments with interest of 10 percent on the deferred payments. Before the sale, Fabulous properly took $500,000 of amortization deductions with respect to the trademark and goodwill, which were deducted against German-source income. What is the source of the income realized? 14. Assume the same facts as in Problem 11, except that the German patent is one of many foreign patents the exploitation of which is handled by a licensing branch office of Fabulous located in Frankfurt, Germany. The gain on the sale of the German patent to Erfurt is exempt from German tax. a. What is the source of the income realized? b. If the patent sold were inventory property, would the source result change? c. If the patent were sold for a royalty-like price, would the source result change