Question: John Carmack is a computer genius and, while unemployed, invents a switching device for high - speed networks. He patents the device but does not

John Carmack is a computer genius and, while unemployed, invents a switching device for high-speed networks. He patents the device but does not reduce it to practice. Mr. Carmack has a zero tax basis for the patent. In consideration of $755,000 plus a $1.50 royalty per device sold, John assigns the patent to a computer manufacturing company. He assigns all substantial rights in the patent. Which of the following is correct?
a.
John automatically has long-term capital gain from the lump-sum payment, but not from the royalty payments.
b.
John automatically has long-term capital gain from the royalty payments but not from the lump-sum payment.
c.
John automatically has long-term capital gain from both the lump-sum payment and the royalty payments.
d.
John does not have automatic long-term capital gain from either the lump-sum payment or the royalty payments.

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