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The Court of Civil Appeals rejected the findings of the circuit court and denied the royalty deductions claimed by VFJ. In doing so:
For the tax year at issue, Lee and Wrangler charged VFJ an arm's-length royalty to use their trademarks.
Code 1975, [section] 40-18-35(b), to effectively deny VFJ a deduction for the Lee and Wrangler royalty payments in calculating the company's Alabama income.
VFJ petitioned the Montgomery County Circuit Court for review contending that the royalty deductions were properly claimed, not subject to add-back (owing to the application of a statutory exception) and, alternatively, that the add-back statute was unconstitutional under the Commerce Clause of the U.S.
[T]hey have economic substance and business purpose and represent real and necessary costs of doing business in Alabama, and to disallow these deductions would distort the amount of VFJ's income fairly attributable to this state.
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