Second Circuit Finds Royalty Payments Need Not Be Capitalized Under Section 263A

The U.S. Court of Appeals for the Second Circuit March 19 ruled in a decision of first impression that royalty payments—calculated as a percentage of sales revenue from inventory—that are incurred only upon…

ANALYSIS: The Tax Court’s Duty to Apply the Properly Applicable Law

Normally the Tax Court, like other trial courts, lets the parties try their cases, and does not further complicate its…