The petitioner transferred several patents to a corporation of which he owned 24 percent. The balance was owned by a related party and the petitioner's friend. The petitioner controlled the corporation and reported the royalty income received from the corporation for the patents as capital gain. The IRS challenged that characterization and the court agreed with the IRS because the petitioner failed to transfer all of the substantial rights associated with the patents due to his control of the transferee corporation. Cooper v. Comr., 143 T.C. No. 10 (2014).