in the Interest of J.R.T.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• precluding deduction from taxable income royalty payments made to a passive investment company
• irrelevant that payments might have been equivalent to those in an arm’s-length transaction because such payments were unnecessary and part of a contrived mechanism
• despite transfer of trademark to subsidiary, substantive business activities connected to mark remained with parent

Source: CourtListener parenthetical corpus (CC0).