An agreement for the assignment by the taxpayer to a drug company of the taxpayer's rights under patent to a medicinal preparation in consideration for a down payment of $1,000, and for $999,000 to be paid at a specified rate for each capsule sold by the purchaser, gave rise to income receipts to the taxpayer under s. 3(1)(f) of the Income War Tax Act. In light inter alia of the right of the purchaser to terminate the agreement whenever the manufacture and sale of the preparation became unprofitable without any obligation to pay the balance of the $999,000, that amount was characterized (p. 400) only as indicating "a maximum amount which, once paid, will discharge the company, rather than an amount which must necessarily be paid by the company for the acquisition of the right ...".
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