§1338

1338(a) (2012) (providing that the Federal District Courts have original jurisdiction over “any civil action arising under any Act of Congress relating to patents”). “Notwithstanding th[e] defined act of infringement, a district court’s inquiry in a suit brought under [35 U.S.C.] § 271(e)(2) is the same as it is in any other infringement suit,

1338(a) (2006) (“The district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents[.]”); see also Sheridan v. Commissioner, T.C. Memo. 2015-25, at *8. 19Dr. Filler often uses patent infringement and inverse condemnation interchangeably. The distinction, however, is that an inverse co

1338(a) (2012) (providing that the Federal District Courts have original jurisdiction over “any civil action arising under any Act of Congress relating to patents”). “Notwithstanding th[e] defined act of infringement, a district court’s inquiry in a suit brought under [35 U.S.C.] § 271(e)(2) is the same as it is in any other infringement suit,

1338(a) (2012) (providing that the Federal District Courts have original jurisdiction over “any civil action arising under any Act of Congress relating to patents”). “Notwithstanding th[e] defined act of infringement, a district court’s inquiry in a suit brought under [35 U.S.C.] § 271(e)(2) is the same as it is in any other infringement suit,

1338(a) (2006) ("The district courts shall have originaljurisdiction ofany civil action arising under any Act ofCongress relating to patents[.]"). Second, petitionerhas raised no genuine issue for trial concerning his ability to substantiate the amount ofhis supposed loss. Taxpayers are required to keep - 9 - [*9] permanent records sufficient