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Robinson Knife Manufacturing Co. v. Commissioner of Internal Revenue

United States Court of Appeals for the Second Circuit

600 F.3d 121 (2010)

Facts

Robinson Knife Manufacturing Company, Inc. (Robinson) (petitioner) sold kitchen tools bearing trademarks licensed from third parties to which Robinson paid royalties. The royalty payments were calculated as a percentage of sales revenue based on inventory accounting and were incurred only upon the sale of that inventory. Robinson deducted the royalty payments on its tax returns as ordinary and necessary business expenses. The Internal Revenue Service (IRS) (defendant) issued a notice of deficiency, arguing that the royalties were required to be capitalized to Robinson’s inventory costs. The tax court agreed with the IRS, and Robinson appealed.

Rule of Law

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Issue

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Holding and Reasoning (Calabresi, J.)

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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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