BROWN, J.
IDC Research, Inc., appeals from a decision of the Appellate Tax Board (board), upholding the refusal of the Commissioner of Revenue (commissioner) to abate a portion of the corporate excise taxes assessed to its parent corporation, International Data Group (IDG), for the tax years 1992, 1993, and 1994. IDG disputes that it owes taxes on royalty income received by IDG Holdings, Inc. (IDG Holdings), an IDG subsidiary incorporated in Delaware.
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