CCM 201014050 (Nov. 16, 2009)

(gross receipts derived from sale of taxpayer's tangible personal property developed via scientific process that is sold in commercial quantities which is then resold to end-users qualifies as DPGR; royalty income and technology fees from licensees that use taxpayer's product not DPGR because licensing of intangible right is not a disposition that gives rise to DPGR; but taxpayer's product to which item developed in scientific process is affixed is tangible personal property from which the gross receipts derived from the sale count as DPGR).