(1) Whether New Jersey's scheme for taxing royalty
payments, that conditions the deductibility of
related-party royalty payments on the extent of
the royalty recipient's in-state activity, burdens
and discriminates against interstate commerce in
violation of the Commerce Clause.

(2) Whether New Jersey's scheme for taxing related party
royalty payments, that limits the deductibility of the
royalty expense to the extent the royalty recipient
pays tax in the state on the royalty income, indirectly
taxes out-of-state activity with no connection to New
Jersey in violation of the Commerce or Due Process
Clauses.

Whether New Jersey's corporate business tax scheme for taxing royalty payments conditions deductibility on the extent of the royalty recipient's in-state activity and thereby burdens interstate commerce