Robinson Knife Manufacturing Co. v. Commissioner of Internal Revenue

600 F.3d 121 (2010)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

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

Issue

Holding and Reasoning (Calabresi, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership