RAPOZA, C.J.
The Talbots, Inc. (Talbots), appeals from a decision of the Appellate Tax Board (board) affirming the refusal of the Commissioner of Revenue (commissioner) to abate certain corporate excise taxes assessed against Talbots. The contested assessments arise from disallowed deductions for royalty payments made by Talbots to a wholly owned subsidiary for the use of various intellectual property. The board found that the transfer and licensing of the intellectual...
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