CCH Federal Taxation Basic Principles
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No General Asset Classes are provided for Code Sec. 197 property. To qualify, the Code Sec. 197 property must be of the same nature or character (e.g., a copyright for a patent is NOT OK; it must be a patent for a patent, or a copyright for a copyright). In addition, the nature or character of the underlying property to which the Code Sec. 197 relates must be like-kind (e.g., a patent on a factory machine for a patent on an airplane engine is NOT OK; however, a patent on an airplane engine for a patent on a helicopter engine IS OK).
Like-Kind Exchanges—Intangible Property
Chapter 11, Exhibit 11b