IRS Nonacq. (IRB No. 2011-9, Feb. 8, 2011)

(IRS announces non-acquiescence in Robinson Knife Manufacturing Co. and Subs. v. Comr., 600 F.3d 121 (2d Cir. 2010), rev'g., T.C. Memo. 2009-9, in which court held that sales-based royalties that taxpayer paid for right to use trademarks on kitchen tools that it manufactured and sold were not production costs "allocable to property produced" (inventory) within meaning of Treas. Reg. Sec. 1.263A-1(e), but are deductible expenses under I.R.C. Sec. 162).